|Type of Data||Purposes of Processing||Legal Basis under the GDPR|
|Website Interaction and Marketing:|
When you interact with our website, we may collect your online identifiers, such as Internet Protocol (IP) address, Cookie ID and other unique identifiers (“Online Identifiers”).
Further, we will collect your behavioral information, which is collected indirectly by our external marketing tools, or analytic tools. This information includes the referring URL (that is, the webpage directing you to our website, and other websites you visited in the session), your interests in our competitors, the web page you visited when you tapped/clicked on our ad, how you interact with our webpage, time, duration of use, pages you have viewed on our website (“Marketing Data”).
|First, Online Identifiers and cookies are used, in particular to operate the website and enable its proper functionality, for security and fraud prevention purposes, debugging purposes and to resolve technical problems. For example, in order to automatically recognize you by the next time you enter the website or to confirm you are a real person.|
Second, the Online Identifiers and the Marketing Data are indirectly processed by third-parties marketing and analytic tools, for analytic and remarketing purposes. We process this data to understand how Prospects use our website and to measure effectiveness of some ads we use in order to track conversions, build targeted audience, and remarket our Services to people who have taken some action on the website.
|Online Identifiers which are collected through cookies we implement, which are strictly necessary for the proper and basic operation of the website will be processed in our legitimate interest.|
Your Marketing Data which are collected through third-party cookies, including any targeting and marketing cookies, will be processed based on your consent which we will obtain through our cookie notice and consent management.
You may withdraw consent at any time by using the cookie preference settings as available in the footer of the website, or by managing opt-out through your browser or device.
In the event you contact us with any inquiries, either through an online form available on the website (i.e., the contact us and support pages, the DSR form, etc.), by sending us an email or by any other means, you will be requested to provide us certain information such as your name, telephone number, email address (“Contact Information”).
|We will use your Contact Information solely for the purpose of responding to your inquiries.|
The correspondence and its contents with you may be processed and stored by us in order to improve our customer services and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).
|We process Contact Information subject to our legitimate interest.|
When registering for a free trial, demo session, webinars or other similar forums, we will send you service communications and marketing promotions, such as new features, additional offerings, special opportunities or any other information we think you will find valuable. (“Direct Marketing”).
|We will use your information in order to keep you updated with offers and content such as service updates, new capabilities and features, surveys, etc.||We process your information subject to our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.|
In the event you sign up to receive our newsletter, blog updates or other marketing materials, you will be requested to provide your contact details, such as your email address.
|We use this information in order to send you the content you requested or other marketing materials.|
We will further store this information in order to include you in our marketing lists, as well as the “opt-out” list (solely the necessary information for such purpose), and to ensure we respect your choice and comply with applicable laws in this regard.
|We process such contact information subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email.|
In the event you choose to provide feedback, post on our website or social media pages, you may be required to provide us with certain additional information such as your role, country, company name, etc.
|We will use this information for the purpose of providing you with the services that you requested.||We process this information subject to our legitimate interest.|
When we contact you through your work phone, we may, subject to applicable laws, record our call (“Call Recordings”).
|We use such Call Recordings in order to enhance our sales efforts, and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).||Subject to applicable laws, we will process our Call Recordings based on your consent.|
In the event you choose to book a free trial you will be requested to provide us with certain information such as your name, your company email address, work phone, working company, your role, country, etc. (“Free Trial Information”).
|We will use your Free Trial Information for the purpose of providing you with the free trial services as requested.|
We will also use your Free Trial Information for Direct Marketing.
|We process your Free Trial Information in order to take pre-contractual steps as you requested. |
We process your Free Trial Information for Direct Marketing purposes based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.
In the event you choose to book a demo session you will be requested to provide us with certain information such as your name, your company email address, work phone, working company, your role, country, etc. (“Demo Session Information”).
|We will use your Demo Session Information for the purpose of providing you with the demo services you have requested.|
We will also use your Demo Session Information for Direct Marketing
|We process your Demo Session Information in order to take pre-contractual steps as you requested. |
We process your Demo Session Information for Direct Marketing purposes based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.
|Webinars and Events:|
In the even you register for a webinar or event we host, you will be requested to provide us with certain information such as your name, your company email address, work phone, working company, your role, country, etc. (“Webinar Information”).
|We will use your WebinarInformation for the purpose of providing you with the demo services you have requested.|
We will also use your WebinarInformation for Direct Marketing purposes.
|We process your WebinarInformation in order to take pre-contractual steps as you requested. |
We process your WebinarInformation for Direct Marketing purposes based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.
In the event you register for a sweepstake we conduct, you will be required to provide us with certain information such as your name, your working company name, business email address and phone number, your business role, country, etc. (“Sweepstake Information”).
|We will use your Sweepstake Information in order to administer your participation in a sweepstake, contact you for winner notification, prize delivery confirmation (where applicable) or other promotional purposes.|
We will also use your SweepstakeInformation for Direct Marketing purposes.
|We process your Sweepstake Information in order to take pre-contractual steps as you requested. |
We process your Sweepstake Information for Direct Marketing purposes based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.
In order to use our Services, you will be required to register and open an account. During the registration process you will be requested to provide us with certain information such as your name, company name, email address, role, and other similar contact information, and you will be able to create a user name and password.
(Collectively “Account Registration Data”).
|We use your Account Registration Data to create and designate your account, authentication and validate access, enable log-in, access and use of your account as well as to send you needed information related to our engagement (e.g., billing and invoicing).|
In addition, we use this information for Direct Marketing purposes, meaning, as our Customer, we may send you marketing related communications (by email or other contact details you have provided), materials and content regarding the Services you are currently using or any services we may offer in the future to keep you up to date, and for example, offers and content such as software updates, new capabilities and features, surveys, etc.
|We process your Account Registration Data for the purpose of performing our contract with you.|
Processing of this information for Direct Marketing purposes is made subject to our legitimate interest. You can opt-out at any time using the “unsubscribe” option within the body of the message.
Please note that if you choose to unsubscribe from our Direct Marketing, we will still retain your contact details and send you service-related emails, such as invoices.
When you contact us for customer support, we will process your Contact Information.
|We will use the Contact Information to provide you with the customer support needed. We will retain such correspondence for as long as needed, and to evidence the support was provided.||We process such information to provide the required support services and fulfill the contractual obligations.|
When you use our Services, information regarding such use is automatically generated and collected, which may include the click stream within the Services, the use of the Services (i.e., accessed or used by Customer) and the time spent on those pages or features, crash data and analytics, etc.
We record how you interact with the Services. We log crashes, interaction with the Services, how often you use the Services, how long you are on the Services, etc.
(Collectively “Usage Data”)
|We use your Usage Data to help us understand how you are using our Services, and how to better provide and improve our Services. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products.|
In addition, we process Usage Data for security, operation and debugging purposes, and for example, to resolve technical errors.
|Where we collect Usage Data for operation and security purposes, we process your data based on our legitimate interest.|
Where we collect Usage Data for analytic and marketing purposes, we process such data based on your consent which we will obtain through our cookie notice and consent management tool.
You may withdraw consent at any time by using the cookie preference settings available in the footer of the website, or by managing opt-out through your browser or device.
When you apply for a job at Panaya, we will process your CV (and the information included therein), as well as additional information such as your contact information (name, email address and phone number), information regarding your education and skills, employment history, and your photo (to the extent provided by you).
Further, where required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability.
In addition, we may collect other information from public and online sources, referees, background checks where applicable, and former employers and combine such data with the data you provided us (collectively, “Recruitment Data”).
|We will use your Recruitment Data to process your job application and for our internal recruitment management purposes, for further recruitment steps (e.g., interview), and to enable Panaya to comply with corporate governance and legal and regulatory requirements.|
Following the completion of the recruitment process, we may further retain and store the Recruitment Data (including other interactions with us under such process) as part of our internal records keeping, including for legal defense from any future claim, as well as, and subject to applicable law requirements, to contact you in the future for other position we believe you qualify for.
If you are hired, your Recruitment Information will be kept on our HR systems as part of your employment and our corporate management.
We currently use Comeet which processes your Recruitment Information on our behalf based on their Privacy Notice available here, and pursuant with Comeet’s contractual commitments under this data processing agreement.
|We process Recruitment Data subject to our legitimate interest.|
In some cases, for example, where we will ask you to provide health related information or diversity and inclusion data, we will process such data based on our obligations in employment and the safeguarding of your fundamental rights.
Where you provided your consent, we will process your Recruitment Data in order to contact you with further job offers which we believe you might be interested in.
|Category of Recipient||Data That Will Be Shared||Purpose of Sharing|
|Service providers||All types of Personal Data||We employ other companies and individuals to perform functions on our behalf. Examples include: outsource consultants, sending communications, processing payments, analyzing data, providing marketing and sales assistance (including advertising and event management), identifying errors and crashes, conducting customer relationship management, and providing training. These third-party service providers have access to Personal Data needed to perform their functions, but they are prohibited, through contractual obligations, from using your Personal Data for any purposes other than providing us with requested services.|
|Affiliated Companies||All types of Personal Data||We may share your Personal Data with our affiliated companies including our parent company, for sales and marketing purposes, providing customer relationship services, etc.|
|governmental agencies, law enforcements or authorized third parties||All types of data||We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.|
We may also share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, or protect the rights, property, or security of Panaya, our Customers or others.
|ACCESS RIGHTS||You further have the right to know which Personal Data we specifically hold about you, and receive a copy of such or access it, if you wish to receive a copy of the Personal Data or Personal Information, please submit a Data Subject Request form (“DSR”) as available here.|
|RIGHT TO CORRECTION||You have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. Please submit a DSR as available here.|
|RIGHT TO BE FORGOTTEN, RIGHT TO DELETION||In certain circumstances, you have the right to delete the Personal Data we hold about you. Please submit a DSR as available here.|
|RIGHT TO PORTABILITY||You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please submit our DSR as available here.|
|RIGHT TO OPT OUT UNDER THE EU, AND SPECIFICALLY IN THE US THE RIGHT TO OPT OUT FROM:|
(I) SELLING PERSONAL DATA;
(II) RIGHT TO OPT OUT FROM TARGETED ADVERTISING; AND
(III) RIGHT TO OPT OUT FROM PROFILING AND AUTOMATED DECISION MAKING
|Direct Marketing: You have the right to opt-out from Direct Marketing, by unsubscribing through the email received.|
Newsletter: You have the right to withdraw consent when you no longer wish to be in our newsletter list.
Cookies: When you no longer wish for cookies to track your behavior for analytic and marketing purpose, change your preferences through the cookie settings available on our website footer.
Sale of Personal Data for targeted advertising, monetary gain or profiling, or Share or Sale of Personal Information for analytic or marketing: If and to the extent applicable, you have the right to opt out of the sale of your Personal Data, for the purposes of targeted advertising, sale to a third party for monetary gain, analytic, etc. as detailed under the here or through the cookie settings available on our website footer.
Last, you are able to install privacy-controls in the browser’s settings to automatically signal the opt-out preference to all websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control, where applicable, subject to your jurisdiction, as a valid request to opt-out of the sharing of information linked to your browser.
Note you may have the right to authorize another person acting on your behalf to opt out (including by technical tools and opt out signals).
|RIGHT TO APPEAL OR COMPLAINT||If we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the EU you have the right to lodge a complaint with the supervisor authority or the Information Commissioner in the UK.|
|NON-DISCRIMINATION||Such discrimination may include denying a service, providing a different level or quality of service, or charging different prices. We do not discriminate our customers or users.|