Data Collection

This Privacy Policy governs the processing and transfer of Personal Data that we, SayMine Technologies Ltd., (d.b.a “Mine”) collect and process in connection with Mine Privacy Portal (“Platform”).

The Platform will help your company (“Customer”) to manage privacy requests.

Our Privacy Policy is part of our Service Agreement and applies to the processing of Personal Data related to you, an employee of a Customer who provided you with access to the Platform. If you have any questions or concerns about this Privacy Policy or Personal Data related to you, please contact us at: portal@saymine.com.

What types of data does Mine collect and for what purposes?

Mine collects personal and non-Personal Data. Let’s start by explaining important terminology:

Definitions:

"Personal Data" means information that identifies or can identify an individual, such as first and last name, email address, profile picture, unique online identifiers, etc.

"Non-Personal Data", means information, usually on an aggregated form, that cannot be linked to a single identifiable individual, taking in mind all means reasonably likely to be used by Mine or by any other person to identify that individual, directly or indirectly.

Personal Data Collected and Processed by Mine

When you use the Platform we process and collect Personal Data for the following purposes:

  • Type of Personal Data - Personal Data provided by you during sign-in and the use of the Platform. Full name, business email address, and any other type of Personal Data that you upload or provide us, as part of the text communications with you or the text communications you manage on the Platform.
  • Purpose of processing - We use this type of Personal Data to perform our duties and obligations to our Customers under the agreement between us, as regards to the Platform, to maintain contact with you, as a representative of our Customer and to provide you with customer service and support.

  • Type of Personal Data - Analytics data regarding the use of the Platform - using tracking technologies, which collect, for example, your internet protocol (IP) address, and technical data transmitted by the device that you are using such as your browser type, operating system type, device type, preferred language, the path you have taken on the Platform, the content you have interacted with, the time and date of your session, directing URLs and general geolocation (such as city).
  • Purpose of processing - We process this type of data to operate and improve the Platform.

  • Type of Personal data - Online identifiers included in Cookies and other tracking technologies (please see our Cookies and Similar Tracking Technologies Policy here).
  • Purpose of processing - We process this type of Personal Data to support our legitimate business interests and as described under "Your EU Data Subjects Rights" section below, for example, to operate, protect, and improve the Platform and its content; for auditing and tracking usage statistics and traffic flow.

  • Purposes relevant to all types of data – We use all types of data that we receive and collect to support our legitimate business purposes, including – to protect the Platform from illegal, fraudulent (such as identity theft), abusive and malicious activities on the Platform; to handle inquiries and complaints, to resolve disputes and to protect legal rights; to support requirements from us under the law, for example, for tax and auditing purposes; and to comply with court orders, warrants and requirements to assist law enforcement agencies.

Non-Personal Data Processed by Mine

We collect non-personal data about the use of the Platform, such as the scope of use, frequency, latency, pages accessed and viewed, interactions with content and materials displayed, and other technical information regarding the type of devices used to access the Platform (for example, through the use of Google Analytics. You can find an explanation about how Google uses data when you use our Platform here).

Non-Personal Data is used mainly for clickstream analysis, to maintain and develop the Platform, to measure and understand the level of engagement with the Platform, for general business analytics for ensuring the technical functioning of our network, to help prevent fraudulent use of the Platform, to protect the website and the Platform from cyber threats and for developing new capabilities and features.

Third parties

Will Mine share Personal Data with Third parties?

Mine shares Personal Data with third parties in connections with the provision and improvement of the Services, such as marketing, data management, analytics, advertisers, support, and maintenance services. We will never sell Personal Data related to you to anyone.

Other than the third parties described above, we share Personal Data only with third parties if necessary to comply with applicable law, a legal or regulatory requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases and the Platform, to take precautions against legal liability, to enforce our agreements and policies, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

We may share Non-Personal Data, aggregated, statistical, and anonymized data for lawful and legitimate business purposes without limitation.

Personal data control

How Can I Control Personal Data Processed or Collected by Mine?

We respect your Personal Data and treat it as our own, with great care. It is yours to manage and therefore we made it very easy for you. You can contact us directly here or via the chat on the Platform.

We make efforts to accommodate individuals’ rights under various laws and regulations. However, not all of them apply to us and to your use of the Platform. If you want to exercise a right that is not covered by our policy and believe that we need to comply with your request, you are welcome to contact us here or via the chat on the Platform.

Access Your Personal Data. You may review Personal Data related to you collected by Mine by contacting us here or via the chat on the Platform.

Delete or Restrict the Processing of Your Personal Data. You may request the deletion or the restriction of processing of Personal Data related to you by contacting us here or via the chat on the Platform. Note that we will comply with such requests in a way that will not compromise our obligations to our Customers under the Service Agreement.

Unsubscribe. At any time, you can request that we will not send you our newsletter and marketing material. It will usually take a few days to remove your details from our distribution list. You can contact us here or via the chat on the Platform to unsubscribe.

Filing a complaint to the authorities. You are entitled to file a complaint with the applicable privacy or data protection regulator in connection with concerns you may have about your privacy and Personal Data related to you. If you are located within the EEA - you have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR.

If you contact us and request to exercise any of the rights detailed above, we may request that you provide us with certain information in order to verify your identity and locate Personal Data related to you.

We will make our best efforts to enable you to exercise your rights as soon as possible and no later than required under applicable laws, unless we need to extend such period, in accordance with applicable laws. In such a case, we will inform you about the extension period and explain the reasons for the delay.

Data retention

We retain Personal Data related to you as long as the Customer uses the Platform. When a Customer decided to delete its Platform account, or if we need to remove the Customer’s Platform account, we will delete Personal Data related to you from our databases within 30 days, following the termination of the Customer’s Platform account or the agreement between the Customer and us, and within 60 days from all backups.

We may need to retain certain details for longer periods of time to comply with legal, tax, and accounting requirements, or if we believe that these details are necessary for current or expected legal proceedings. We make efforts to keep the retained data to the minimum necessary and for periods no longer than required.

Non-Personal Data, statistical, or anonymized data is retained by us without limitation of time.

Security of Data

We use physical, technical, and administrative security measures for the Platform that we believe comply with applicable laws and industry standards. These measures are designed to help us prevent Personal Data related to you from being accessed without proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

Please bear in mind that the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect Personal Data related to you, we, like anyone else, cannot fully guarantee the security of data transmitted via the Platform.

If a data incident that involves Personal Data related to you occurs, we will take maximum efforts to contain the incident, minimize the risks to the extent possible and, if required by applicable laws, provide you with a notification about the incident.

Your EU Data Subject Rights

If the General Data Protection Regulation 2016/679 ("GDPR") applies to the processing of Personal Data related to you by us, then the following terms apply:

Under the GDPR, when we process Personal Data of our Customers on their behalf, we are a data processor. However, while processing Personal Data related to you, as described under this Privacy Policy we are a data controller, and the processing is based on the following lawful grounds:

  • We will process your contact details to perform the contract with you and you employer - the Customer.
  • We will rely on our legitimate Interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
  • ~Communications with you, including direct marketing, for example, when you make contact with us through the Platform;
  • ~Cyber-security;
  • ~Support, customer relations and service operations;
  • ~Enhancements and Improvements to your and others' experience with our Platform and other services;
  • ~Fraud detection and misuse of the Platform.
  • We will process Personal Data related to you to comply with a legal obligation and to protect you’re and others' vital interests.
  • All processing of Personal Data related to you which are not based in the lawful grounds indicated above, are based on your consent.

In addition to your rights under other sections in this Privacy Policy, you have also the following rights:

  • At any time, contact us if you want to withdraw you consent to the processing of Personal Data related to you. Exercising this right, however, will not affect the lawfulness of processing based on your consent before its withdrawal.
  • You may ask to rectification of inaccurate Personal Data related to you.
  • You may ask to transfer Personal Data related to you in accordance with your right to data portability.
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.

If you exercise one (or more) of the rights under this Section or those which are mentioned-above - you may request that third-parties that hold Personal Data related to you will act accordingly.

A summary and further details about your rights under EU data protection laws, is available on the EU Commission's website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will further ask you questions to understand the nature and scope of your request.

Transfer of personal data

Will Mine transfer Personal Data internationally?

We keep Personal Data related to you on servers located in the European Union. However, we use service providers, such as our customer support service, who need to use certain Personal Data to help us provide our Customers with the Platform services. They keep the data in other countries, as well, including in the United States.

If laws that apply to the transfer of Personal Data related to you under this policy, require us to provide further details about the destination of Personal Data related to you and your consent to the transfer, then please note that these companies may keep their data in various countries and that the data protection rules may be different than those in your country of residence.

Your consent to this policy means that you also explicitly consent to such data transfer.

If you are located in one of the European Economic Area countries, we will rely on the fact that Israel Is deemed to provide an adequate level of data protection (following 2011/61/EU: Commission Decision of 31 January 2011 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data by the State of Israel with regard to automated processing of personal data) in order to transfer Personal Data related to you to such territory. We will transfer Personal Data related to you to other jurisdictions, which are not subject to adequacy recognition by the European Commission, by using appropriate safeguards, in particular, by way of entering into the European Union (EU) Standard Contractual Clauses as amended from time to time with the relevant recipients, or by adhering to equivalent data transfer regulations to protect the security and confidentiality of Personal Data. You can obtain a copy of the suitable safeguards that we use when transferring Personal Data as described above by contacting us at: privacy@saymine.com.

Changes and updates

We will update this Privacy Policy from time to time. We will post substantial modifications to this Privacy Policy on the Platform and will notify you via email.

Substantial changes will take effect 30 days after they are posted. Other changes will take effect within 7 days. Please note that changes in laws and regulations may require us to modify this policy within shorter periods of time.

Contact us

If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at -

Say Mine Technologies Ltd.
23 Derech Menachem Begin,
Tel Aviv-Yafo, 6618356 Israel
privacy@saymine.com

For EU residents

Rickert Rechtsanwaltsgesellschaft mbH
Colmantstraße 15
53115 Bonn, Germany
art-27-rep-mine@rickrert.law

For United Kingdom residents

Rickert Services Ltd UK
PO Box 1487
Peterborough, PE1 9XX
United Kingdom
art-27-rep-mine@rickrert-services.uk

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