Privacy Policy

The Personally Identifiable Information That You Provide Us

We receive and store any information you enter when using our Websites or give us in any other way.

When you sign up for and/or attend a Skai event or webinar.

You provide most of your information through forms you fill out on our Website to contact us.
When you contact us, or when we contact you, we will receive and process any personally identifiable information that you provide us.

In addition, when you use the Website, we monitor your use thereof and maintain this usage information as well.

If you are a candidate applying for a position, please see our Recruitment Privacy Policy.
Note that you are not required by law to provide us with any information about you. However, not providing certain personally identifiable information may, in some circumstances, prevent us from providing our Customers the Skai Services as intended.

The Personally Identifiable Information That We Process

We (or others on our behalf) may collect the following types of personally identifiable information about You:

• Website activity information – whenever you use the Website, we monitor your use and record your activity therein. The information that we gather about you in this context includes any activity that you perform in the Website, such as dates and times on which you use them, your interaction with them, etc.;
• Communication information – when you contact us, though any channel whatsoever, you may provide us with your full name, e-mail address, job description, telephone number and the content of your communication with us.

Aggregate Information – we will also create statistical, aggregated and anonymized data relating to You including business development and service improvements. Aggregated data is derived from personally identifiable information but in its aggregated form it does not relate to or identify any particular Customer or individual. This data is used to understand our customer base and to develop, improve and market the Skai Website.

What Do We Do with Personally Identifiable Information?

We use the personally identifiable information we collect and receive to the following purposes:

• to communicate with you and respond to any requests for information;
• to fulfil our contractual obligations,
• to ensure the security of the Websites,
• to analyse trends,
• to administer the Websites,
• to improve our products and services,
• to better understand our customers and users and the way use and interact with our Websites, including their user experience,
• to send you news and updates about our products and services,
• to gather demographic information about our user base as a whole, and
• to communicate with you in connection with our events and webinars. After an event/ webinar we may contact you about such event/ webinar and related Skai products and services.
• To conduct surveys and send questionnaires; We process personally identifiable information related to prospective customers who engaged us through our website. This information will only be used for the purpose of evaluating, contacting and serving the prospective customers.

We will use the contact details you provide us (including e-mail address and phone number) in order to contact you for operational and service-related matters. Moreover, subject to the requirements of the applicable laws, we may use your contact details -for the purpose of providing you commercial materials related to our current and/or future products and services. You can unsubscribe from our marketing mailing lists by sending an opt-out request to privacy@clearskai.com.

We obey the law and expect you to do the same. If necessary, we will use personally identifiable information related to you to enforce our terms, policies and legal agreements, to comply with applicable laws, court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service, and to take any action in any legal dispute and proceeding.

We commit to process personally identifiable information solely for the purposes described in this policy.

Sharing Personally Identifiable Information with Others

We do not sell, rent or lease your personally identifiable information. We will share personally identifiable information related to you to support our services and operations with third parties. These third parties include service providers such as hosting services, customer support, security providers, etc.. Such third parties are committed to protect your privacy as required under the applicable law.

We will also share your personally identifiable information with our affiliates. These mean companies within the Company group and include subsidiaries, sister-companies and parent companies, with the express provision that their use of your personally identifiable information will comply with this policy.

We will disclose or use Your data to defend or enforce our legal rights and in accordance with any applicable law. We will disclose personally identifiable information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We may also share your personal information with our partners, for example, if we collected your information in joint marketing activities (events/webinars) with a partner, we may provide your Personal Information with that partner.

Additionally, a merger, acquisition or any other structural change will require us to transfer your personally identifiable information to another entity, as part of the structural change or of the negotiations therefor, provided that the receiving entity will comply with this policy.

We will share your personally identifiable information only subject to the terms of this policy, or subject to your prior consent.

Analytics and Marketing Automation

We use third parties’ analytics tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content. We also use third party marketing automation tools to help us with our marketing efforts.

We use the standard analytics tools of Google Analytics we will use additional or other analytics tools, from time to time, to learn about how you and other users use the Service, in support of our Service-related activities and operations.

The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: https://www.google.com/analytics/learn/privacy.html.

These service providers use cookies, pixel tags or other technologies to collect and store information. You can prevent analytics and marketing automation services from recognizing you by disabling third party cookies on your web browser, as further detailed in our Cookies and Similar Tracking Technologies Policy.

In addition, we use anonymous, statistical or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to you.

Information Security

We and our hosting services implement systems, applications and procedures to secure data we collect and process, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Website will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Data Retention

We retain the different types of personally identifiable information that we maintain only for as long as necessary for the fulfilment of the purposes for processing the information, or for longer periods, if we find in necessary to comply with legal requirements applicable to us under the applicable law.

We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

Your Choice

At any time, you can unsubscribe from our marketing mailing lists by sending an opt-out request to privacy@clearskai.com. Please note that if you opt out of receiving marketing communications from us, we may still communicate with you from time to time if we need to provide you with non-marketing information about the Services or for other legitimate non-marketing reasons.

At any time, you can stop using our website.

At any time, you can exercise your following opt-out options:

• Cookie opt-out – You may elect to opt-out of enabling third party other types of cookies in your browser’s settings tools. For further information about cookies, please see our Cookie Policy.

You can also exercise your choice by contacting us at: privacy@clearskai.com.

Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on a service or through cross-site user tracking. Our Website does not respond to DNT signals.

Accessing Your Personally Identifiable Information

At any time, you can contact us at: privacy@clearskai.com and request to access the personally identifiable information that we keep about you. We will ask you to provide us certain credentials and/or information to make sure that you are who you claim to be and to the extent required under the applicable law, will make good-faith efforts to locate your personally identifiable information that you request to access.

If you are eligible for the right of access under the applicable law, you can obtain confirmation from us of whether we are processing personally identifiable information about you, and receive a copy of that data, so that you could –

• verify its accuracy and the lawfulness of its processing;
• request the correction, amendment or deletion of your personally identifiable information if it is inaccurate or if you believe that the processing of your personally identifiable information is in violation of the applicable law.

We will use judgement and due care to redact from the data which we will make available to you, personally identifiable information related to others or that reveals proprietary information of the Company.

Specific Provisions for California Residents

This section applies solely to users of our Website who reside in the State of California.

The personal information that we collect

In the preceding twelve (12) months we have collected the following categories of personal information:

• Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as names, telephone numbers, business postal addresses, Internet Protocol address, email address and the time and value of a Transaction.
• Website usage information.
• Information gathered as part of communication between us.
• Commercial information related to transactions with Customers.
• Internet or other similar network activity.
• Inferences drawn from other personal information.

Our business purposes for collecting your personal information

We collect your personal information for various business purposes, all as described above under the section titled What Do We Do With Personally Identifiable Information.

The categories of sources from which your personal information is collected

We obtain the categories of personal information listed above from various sources, including directly from Users and our website’s visitors, from your Website activities and from third party service providers, as further described above under the section titled The Personally Identifiable Information That We Collect.

The categories of third parties with whom we share your personal information

We may share your personal information with various third parties such as our service providers and our affiliates, as further described above under the section titled Sharing Personally Identifiable Information with Others.

The categories of personal information disclosed to said third parties:

In the preceding twelve (12) months we have disclosed the following categories of personal information for business purposes:

• Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as names, telephone numbers, business postal addresses, Internet Protocol address, email address and the time and value of a Transaction.
• Website usage information.
• Information gathered as part of communication between us.
• Commercial information related to transactions with Customers.
• Internet or other similar network activity.
• Inferences drawn from other personal information.

In the preceding twelve (12) months, we have not sold personal information. However, since the CCPA and CPRA define the term “sale” very broadly to include any exchange of data for consideration of any kind, depending upon the circumstances, our sharing of personally identifiable information with other entities to assist us with targeted advertising might amount to the “selling” of personal information.

Your Rights as a California Resident

You are entitled to the following specific rights under the CCPA and the CPRA in relation to your personal information:

Access to Specific Information and Data Portability Rights

You have the right to request that we will disclose certain information to you about our collection and use of your personal information over the past 12 months. After verifying your request, we will disclose to you:

• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting that personal information;
• The categories of third parties with whom we share that personal information;
• The specific pieces of personal information we collected about you;
• If we disclosed your personal information for a business purpose, we will provide you with a list which will identify the personal information categories that each category of recipient obtained.

Correction Right

Taking into account the nature of the personal information and the purposes of the processing thereof, you have the right to request that we correct inaccurate personal information about you.

Deletion Rights

You have the right to request that we delete your personal information. Upon confirmation of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception under applicable law applies.

Right to non-selling

We may share personal information about you with third parties in ways that may constitute a “sale” under the CCPA and CPRA. You may request that we not “sell” your personal information on a going-forward basis. To do so, please contact us at: privacy@clearskai.com, and include your name, email address and/or Company name.

We shall not discriminate against you because you exercised any of your rights under the CCPA or CPRA.

Exercising Your Rights

To exercise the rights described above, please submit your request to us by sending an email to: privacy@clearskai.com.

Only you or a person authorized to act on your behalf, may make a request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

A request for access can be made by you only twice within a 12-months period.

We cannot respond to your request or provide you with the requested personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use the personal information provided in your request to verify your identity or authority to make the request.

We will do our best to respond to your request within 45 days of its receipt. If we require more time (up to additional 45 days), we will inform you of the reason and extension period in writing. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures that we provide will only cover the 12-month period preceding receipt of your request.

The response we provide will also explain the reasons for our inability to comply with your request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request.

Your EU Data Subject Rights

If EU data protection laws apply to the processing of personal data related to you by Company, then the following terms apply:

Under EU data protection laws, Company, will be considered a data controller as such term is defined therein, with respect to the processing of personal data about You.

Our EU Representative can be found at:
Rickert Rechtsanwaltsgesellschaft mbH
– Kenshoo d/b/a Skai –
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-skai@rickert.law.

With respect to the processing activities that we perform as a data controller and which are covered by this policy, the processing is based on the following lawful grounds:

• All processing of your personal data which are not based on the lawful grounds indicated below, are based on your consent.
• We process your account and usage details to perform the contract with you (or, with the entity on behalf of which you operate as a representative).
• We will process your personal data to comply with a legal obligation.
• We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms.

Where the legal basis for the processing of the personal data about you is for its being necessary for the purposes of the legitimate interests pursued by us, you may, at any time, approach us by sending a notice to the email address privacy@clearskai.com, in order to receive information concerning the review performed by us. This is so you can conclude that we may process the personal data about you on account of such processing being necessary for the purposes of the legitimate interests pursued by us.

In addition to your rights under other sections in this policy, and subject to the limitations and restrictions of the EU data protection laws you have the following rights:

• AT ANY TIME, CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA. EXERCISING THIS RIGHT WILL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.
• Request to restrict access to your personal data, if this right is applicable under the circumstances. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
• If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold your personal data, in accordance with this policy, will act accordingly.
• You may ask to transfer your personal data in a structured, commonly used, and machine-readable format, in accordance with your right to data portability.
• You may object, on grounds relating to your particular situation, to the processing of personal data about you that is based on the legitimate interests pursued by us, including profiling based on such legitimate interests.
• You may object to the processing of your personal data for direct marketing purposes. Additional information about this right is available under the Choice section in this policy.
• 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.
• 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.

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 or information 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.

If we need to delete your personal data following your request, it will take some time until we completely delete residual copies of your personal data from our active servers and from our backup systems.

If you have any concerns about the way we process your personal data, you are welcome to contact our privacy team at: privacy@clearskai.com, or write to us to: Skai Ltd., 30 Ha’barzel St., Tel-Aviv, Israel 6971010. We will look into your inquiry and make good-faith efforts to respond promptly.

Transfer of Data Outside Your Territory

We store and process information in various sites throughout the globe, including on sites operated and maintained by cloud-based service providers.

We make sure that our service providers who process personal information on our behalf provide us with adequate confidentiality and security commitments.

If you are a resident in a jurisdiction where transfer of your personally identifiable information to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer. You can contact our privacy team at: privacy@clearskai.com for further information about data transfer.

If the transfer of personally identifiable information related to you is governed by GDPR, we transfer such personally identifiable information to our various service providers, which have their place of business outside the European Economic Area (EEA), including in the U.S. Therefore, on each time where personal data which is subject to the GDPR may be transferred outside the EEA, we will take all steps reasonably necessary to ensure that your personal information is subject to appropriate safeguards as are required by virtue of the EU privacy laws, including entering into contracts that require the recipients of personal information to adhere to data protection standards that are considered satisfactory under EU privacy laws and other applicable legislation. For more information about these safeguards, please contact our privacy team at: privacy@clearskai.com.

Links To Websites of Third Parties

The Website may provide links to websites and/or applications of third parties. We do not control such websites and applications, nor the collection and/or processing of personal information about you by such websites and applications, and we are not responsible for such websites and applications, nor for their privacy and data protection policies and activities. This policy does not apply to any actions taken via such websites and/or applications.

Whenever you access such third parties’ websites and/or applications, we recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any personal data about you.

Dispute Resolution

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this policy, to update the policy when we believe that we need to, and to verify that we display the policy properly and in an accessible manner. If you have any concerns about the way we process personally identifiable information related to you, you are welcome to contact our privacy team at: privacy@clearskai.com, or write to us. Our address is published on our website at: clearskai.com and, if applicable, is indicated in your subscription agreement with us.

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

We commit to resolve complaints about your privacy and our collection or use of personally identifiable information related to you. European Union individuals with inquiries or complaints regarding this privacy policy should first contact our privacy team at: privacy@clearskai.com.

Changes to this Privacy Policy

From time to time, we will update this policy. If the updates have minor if any consequences, they will take effect immediately after we published the revised policy in the website. In case that we will make substantial changes to this policy, we will strive to inform you about such changes via means of communication we believe are reasonably appropriate to inform you of such amendments and by publishing a notice about such amendments on the Website.

Contact Us:

For further information, please contact our Privacy Compliance at: privacy@clearskai.com and our EU Representative at:
Rickert Rechtsanwaltsgesellschaft mbH
– Kenshoo d/b/a Skai –
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-skai@rickert.law.