TITAN PRIVACY POLICY

Last updated: 29, September 2022

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, FormLogic Ltd. (“Titan”, “us”, “we” or “our”) use, collect and store personal information from or about you (“you”) in connection with https://titandxp.com/ (the “Website“) and the services provided therein (the “Services”).

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement material changes in the way we use your information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.

1.              WHAT PERSONAL INFORMATION WE COLLECT

1.1.         Information provided through the Services. We collect personal information that you voluntarily provide, such as your full name, email address, password, SalesForce account details, as well as any other information that you decide to provide us. We also collect the contact and billing information of our customers. 

1.2.         Information provided through the Website. When you use the Website, we collect and process full name, email address, when you interact with the Website, for example, when you register for the Titan’s Academy or send us a request for a demo or contact us (including, the chat).

1.3.         Information automatically collected. We may automatically collect certain information through your use of Titan’s Services and Website, such as cookie, pixels, tracking technologies and similar identifiers (“Technologies”), your Internet protocol (IP) address, and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of Titan’s Services and Website.  

1.4.         Information from Other Sources. Titan may also obtain information about you from other sources, including publicly – or commercially- available information, and through third-party data platforms, partners and service providers.

 

2.              The purposes for which we collect and use your personal information.

2.1.         We use your personal information for some or all of the following purposes:

2.1.1.            To provide you with the Services. Titan will use your information to provide the Services, including: (i) to allow you to register and log-in to the Services; (ii) to allow you to make use of the Services; (iii) to allow you to create your admin user and to generate regular users and administer their privileges, (iv) we will use your personal information in order to authenticate you and allow you to access the Services; (v) to communicate with you, provide you with support and maintenance; and (vi) to personalize your experience with the Services.

2.1.2.            For Administrative Purposes. Titan may use your information (i) to respond to your questions, comments, and other requests for support, or information; (ii) to provide you with the Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) for testing, research, analysis, and product development, including to develop and improve our Services, and in connection with providing and maintaining our Services; and (vi) to generally administer the Services.

2.1.3.            To Market Titan and our Website and Services. Titan may use information to market Titan, its Website and Services. Such use includes (i) notifying you about offers and services that may be of interest to you that we offer and/or that we offer jointly with or on behalf of other organizations; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in Titan’s Website and Services; and (v) other purposes disclosed at the time you provide personal information.

2.1.4.            To allow you to make use of our Website. We will use your information to allow you to make use of our Website, including, (i) if you request a demo, we will use your personal information to process and answer your request for a demo; (ii) to allow you to register and log-in to the Titan Academy; (iii) to answer your questions and to allow you to communicate with us (e.g., by using the Website chat); (iv) to analyze your use of our Website and to improve our Website; and (v) to customize your experience. 

2.1.5.            Security purposes. Some of the abovementioned information will be used for detecting, and taking steps to prevent and prosecute fraud or other illegal activity; to identify and repair errors; to conduct audits and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, for law enforcement purposes, and/or to exercise or defend legal claims.

2.1.6.            De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. We use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experiencewith them).

2.1.7.            Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Website and Services, may use Technologies to automatically collect information through the Website and Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and Services. If you would like to opt out of the Technologies we employ on the Website and/or Services, you may do so by blocking, deleting, or disabling them as your browser or device permits. For more information, see our cookie notice.

 

2.2.         The lawful bases we rely on for processing personal information are (if and when applicable):

2.2.1.            The data subject has given consent to the processing of his or her personal data;

2.2.2.            Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; and/or

2.2.3.            Processing is necessary for the purposes of the legitimate interests.

 

3.              Disclosure of personal information to third parties

3.1.         We do not disclose or share your personal information with third parties except to provide you the Website and/or Services you have requested, or under the following circumstances:

3.1.1.            We may share some information with our partners (e.g., Salesforce).

3.1.2.            We use third-party service providers to process your information for the purposes outlined above, including, without limitation:

                  i.                   With cloud service providers for hosting purposes;

                  ii.                   With websites and web content creation platforms in order to help us manage our Website and Services;

                  iii.                   With email providers, marketing, CRM and other similar tool provid

                  iv.                   Identity providers, in order to securely manage user accounts, and implement access control;

                  v.                   Log-processing services in order to store and process logs to improve the product, detect and fix problems, and provide you with support;

                  vi.                   The chat option on our Website; and

                  vii.                   With analytic companies, in order to help us understand and analyze the information we collect in the context of the Website and the Services.

3.1.3.            To the extent necessary, with regulators, courts, banks, or competent authorities, to comply with applicable laws, regulations, and rules (including, without limitation, federal, state, or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Titan, our Services, customers, employees, property, and the public.

3.1.4.             If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares, or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.

3.1.5.            Where you have otherwise provided your consent to us for sharing or transferring your information.

If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to privacy@formtitan.com.

 4.              Our use of cookies and other activity tracking technologies

4.1.         Cookies: We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and/or the Services. If you would like to opt out of the Technologies we employ on the Website and/or Services, you may do so by blocking, deleting, or disabling them as your browser or device permits. For more information, please consult our cookies policy https://titandxp.com/cookie-policy/.

4.2.         Analytics tools:

                 i.                   Google Analytics – The Website uses a tool called “Google Analytics” to collect information about the use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with the personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

                 ii.                   Facebook Pixels. We use Facebook pixels, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers), and others to integrate, use and exchange information with Facebook (Meta), as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your Websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

                  iii.                   We reserve the right to remove or add new analytic tools.                                                                       

5.              Security, and data retention

5.1.         Security – We have implemented appropriate technical, organizational, and security measures designed to protect your personal information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device, or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

5.2.         Retention of your personal information – We may retain your information (including personal information) for any lawfully permitted period of time. In addition, please note that in some circumstances we may store your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings and/or (iv) backup, archival, and/or audit purposes. Regarding retention of cookies, you can read more in our cookie policy.

 6.              Cross-border personal information transfers

6.1.         We store and process personal information with AWS with servers located in North Virginia, United States, and or/ in Germany, European Union.

6.2.         In order to run our business and provide our Website and Services to you, we transfer personal information to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction (e.g., the United States). Therefore, your personal information may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever we make such transfers, we will use commercially reasonable efforts to implement an appropriate level of protection to your personal information by implementing at least one of the following safeguards:

                i.            making sure the destination country has been deemed to provide an adequate level of protection for personal information; and/or

                ii.            by executing implement data onward transfer instruments such as data processing and protection agreements.

 7.              Your privacy rights. How to delete your account

7.1.        The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

                  i.                   You have the right to withdraw consent to the processing, where consent is the basis of processing.

                  ii.                   You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.

                   iii.                   You have the right to demand rectification of inaccurate personal information about you.

                   iv.                   You have the right to object to unlawful data processing under certain conditions.

                   v.                   You have the right to the erasure of past data about you under certain conditions.

                   vi.                   You have the right to demand that we restrict the processing of your personal information, under certain conditions (e.g., if you believe that the processing is no longer necessary).

                   vii.                   You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.

                   viii.                   The personal information we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by Titan by contacting Titan directly or by following the instructions through the unsubscribe options in our email messages.

7.2.         You can exercise your rights by contacting us at privacy@formtitan.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

7.3.         Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to privacy@formtitan.com. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

8.              Our Interactions with Children. Our Website and Services are not intended for children and we do not permit children to register on them. If we become aware that we have inadvertently received or collected personal information pertaining to a child under the age of consent in the jurisdiction where the child is located without valid consent, we will remove such information from our records. If you believe that a child has provided us with personally identifiable information without the consent of his or her parent or guardian, please contact us at privacy@formtitan.com

 9.              Interaction with Third Party Products. We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

 10.           Specific Provisions Applicable Under California Privacy Law

10.1.      Our California Do Not Track Notice:

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers

11.           Contact us. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@formtitan.com.

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