1. Our Commitment to Privacy
Your privacy is important to us. For better protecting your privacy we, “Topicx” by Topicx Customer Experience Systems Ltd., a registered Israeli Company, provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and every other page of our websites.
2. The Data We Collect
Data you provide about yourself and your business - For example, when you register for our services, contact us, or use other features on our services that requires input, we will store and save the information you provide. This information may include individual personally identifiable information such as your name, postal address, email address, etc.
Data you provide about your customers - This information may include individual personally identifiable information such as names of those customers, their phone numbers, their address, their emails, etc. (Both types of information shall be referred to as “Personal Data”).
Data we collect by ourselves - Log Data - All information sent by your web browser and computer when you visit our services may be stored by servers we use. This information may include your IP address, browser type, URL accessed, cookie information, the date and time of your request, and other information that may uniquely identify you and may also be considered as part of your Personal Data.
You are the sole responsible for all consents required to be collected and obtained, according to the applicable law, from the data subjects (your contact persons and your customers). It is your responsibility to not provide the Company’s services to your customer which is not providing you the required consents, or he is objecting the process of his Personal Data. For further information in this respect please see the relevant provisions in the DPA (as defined below).
Special Categories of Data - There are special categories of personal data, data which reveals or contains: racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation (hereinafter: “Special Categories of Personal Data”) and therefore is more sensitive.
We request that you do not provide us any Special Category of Personal Data via our services or in any other way, but it is important that you understand that part of the Personal Data which we may collect from your customers for you, may be considered as Special Category of Personal Data, and this kind of Personal Data will be collected and be used or processed otherwise only according to an appropriate lawful basis, as further specified below, and according to the DPA (as defined below) which will be executed between us, and for the purpose of providing you the relevant services of the Company.
Without derogating from the above, you acknowledge and understand that such Special Categories of Data may be processed by us for you as part of the services we provide to you, hence it is your sole and full responsibility to obtain all EXPLICIT CONSENTS TO THE PROCESSING OF THOSE PERSONAL DATA FROM YOUR CUSTOMERS.
Automated individual decision-making - Profiling - The data subject (your customer) must have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. For that, you as Topicx customer, must obtain explicit consent for such profiling.
Topicx platform is using the conversations’ content of your customers as well as meta-data and analytics collected during these conversations to perform personality and cognitive profiling of your customers. The data is used for personalizing the dialogues and offers to your customers as part of your services to your customers.
The Service may also use traffic data and other technical information (device type, log files etc.) processed by cookies and similar tracking technologies, in order to analyze the data subject’s profile. Such data shall be collected and analyzed only after the data subject was duly informed about it by you, followed by an explanation on the profile assessment to be produced from such data, demonstrating why such assessment is relevant and necessary for the performance of the services provided to him by you.
Information relating to a legal entity (e.g. corporate information, corporate contact details, accounting information, etc.);
Anonymized data, namely information which does not relate to an identified or identifiable natural person or to Personal Data rendered anonymous in such a manner that the data subject is not or no longer identifiable.
3. Use of Personal Data
We use the Personal Data to make our services available to you, to conduct statistical analysis, provide customer support, to undertake necessary security and identify verification checks, to meet certain business requirements, in order for us to improve the services and/or customer service. We may also use the Personal Data to track your use of the services and/or for other internal purposes, such as evaluating, providing, and improving the services and for any other purpose related to the operation of the services we provide you.
The Personal Data may also be used by us to provide you with promotional offers and information regarding products and services from us and from third parties. If you do not wish to receive such promotional messages or calls, you may notify us at any time or follow the instructions contained in the promotional communications you receive.
We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information, which we believe, may be of interest or relevance to you, based on your information.
4. Lawful Bases for Processing
Consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the services you have requested), legal obligation (to comply with a common law or statutory obligation), vital interest (to protect someone’s life), public task (to perform a specific task in the public interest that is set out in law) and for legitimate interests.
Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time, and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your Personal Data, please contact us at email@example.com.
5. Personal Data Sharing and Transferring
Sharing of Personal Data mayoccur (i) if you have requested and/or agreed that the Personal Data will beprovided to third parties; or (ii) if the disclosure is required by law; or(iii) if it is transferred for the performance of a contract between you and us;or (iv) the transfer is necessary in order to protect the vital interests ofthe data subject; or (v) the transfer is necessary or legally required onimportant public interest grounds, or for the establishment, exercise, or defenseof legal claims; or(vi) if the transfer is for the purposes of the legitimateinterests pursued by Topicx or by the relevant third party.
In the event that we sell,assigns or transfers some or all of our business or assets to a successor oracquirer, or if we are acquired by or merges with a third party, or if we filefor bankruptcy or becomes insolvent, we may disclose, sell, assign or transferall of your Personal Data as part of the transaction.
Transfer of Personal Data outside the EEA
6. Data Security
To prevent unauthorized access, maintain data accuracy, and ensure the correct use of Personal Data, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, we cannot guarantee the security of your data, which may be compromised by unauthorized entry or use of our services.
We implemented and will maintain and follow appropriate technical and organizational measures intended to protect information that we collect against accidental, unauthorized or unlawful access, disclosure, alteration, loss, or destruction.
7. Security Incident Notification
If we become aware of any unlawful access to any information we stored, or unauthorized access to it, resulting in loss, disclosure, or alteration of the information, we will, according to the DPA, promptly (1) notify you of this security incident; (2) investigate this security incident and provide you with detailed information about the security incident; and (3) take reasonable steps to mitigate the effects and to minimize any damage resulting from the security incident.
Notification(s) of those security incidents will be delivered to you by any means we selects subject to the DPA. It is your sole responsibility to ensure you maintain accurate contact information on the services portal. Our obligation to report or respond to such security incident is not an acknowledgement by us of any fault or liability with respect to a security incident.
You must notify us promptly about any possible misuse of your accounts or authentication credentials or any security incident related to the services that we providing to you.
8. Our Commitment to Children's Privacy
Protecting the privacy of the very young is especially important. For that reason, our services are not directed towards and may not be used by persons under the age of 18, and no part of our website is structured to attract anyone under the age of 18.
9. Links to Other Sites
10. Retention and Deletion of Data
Please note that permanently deleting your account erases all of your information and after completing this process, you can no longer use any of your our services, your account and all its data will be removed permanently, and we will not be able to restore your account or retrieve your data in the future. If you contact us in the future, the system will not recognize your account and we will not be able to locate the deleted account.
11. How You Can Access or Correct Data
You can access and maintain much of the Personal Data that we collect online by connecting us through our contact information. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.
We provide registered users with the ability to correct, delete, or block their data, or make such corrections, deletions, or blockages on their behalf.
12. DPA and Security
For the services provided by us, Topicx is a Processor (as defined in the General Data Protection Regulation (EU) 2016/679 (“GDPR”), acting on your behalf (registered user of Topicx’s services), while you are acting as a Controller (as defined in the GDPR). As data processor, Topicx will only act upon your instructions, and according to Data Processing Agreement that you can find in the following link www.topicx.il/dpa (the “DPA”).
It is hereby clarify, that the services provided to you is subject to your full execution and compliance with the DPA.
As data Controller, you are responsible for the security, integrity and authorized usage of your customers’ Personal Data, and for obtaining all of the required legal basis for processing their Personal Data according to all applicable law, and as applicable, including the GDPR.
Topicx shall engage other sub-processors in according to the provisions of the DPA.
In assessing the appropriate level of security, account shall be taken of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.
Topicx shall take steps to ensure that any natural person acting under the authority of Topicx who has access to Personal Data does not process them except on instructions from Topicx, unless he or she is required to do so by Union law.
Topicx shall notify you without undue delay after becoming aware of a personal data breach.
13. You’re Rights
In certain circumstances, you have rights in relation to the Personal Data we process about you. The table below sets out an outline of those rights and how to exercise them:
Please note that Topicx will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email firstname.lastname@example.org. Please note that for each of the rights below, Topicx may have valid legal reasons to refuse your request, in such instances Topicx will let you know if that is the case.
14. Your Acceptance of this Policy
16. How to Contact Us
Should you have other questions or concerns about these privacy policies and if you believe that we are not adhering to our privacy or security commitments, please send us an email to at email@example.com
Last updated and effective as of Oct 7st 2020.