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Privacy policy

Last Updated: August 7, 2023

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Strigo Ltd. and its affiliates (collectively, "Strigo", "we", "us" or "our") is committed to protecting your privacy and ensuring you have a positive experience when you use our education and training software-as-a-service solutions, including  Strigo Classroom, Strigo Labs, and any other products and services described on one or more applicable order forms  (collectively, the "Services"), visit the Strigo website, as well as any other site or application that may be used to access the Services (collectively, the "Website"), and any other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with us.

This Privacy Policy explains Strigo's practices when we collect, process and mange information that relates to an identified or identifiable individual, including information that Strigo can associate with an individual person ("Personal Data"), in the context of providing the Services and operating the Website, whether such individual: (i) uses the Services as our business Customer (each, a "Customer"; collectively, "Customers") or as a participant or an end user of a Customer ("End User(s)"). We use such Customer or End User Personal Data on behalf of and under the instruction of the respective Customer, in accordance with our Data Processing Addendum with them. Accordingly, this Privacy Policy (which describes Strigo's privacy and data processing practices) does not apply to the privacy and data processing practices of our Customers. To learn about the privacy policy and practices of our Customers, please contact them directly. (ii) sets up and operates an account on behalf of a Customer using the Services, including the account administrators and users, billing contacts and authorized signatories on behalf of the Customer ("Authorized Representative(s)"); (iii) visits the Website, makes enquiries, requests a demo of the Services or otherwise contacts us ("Website Visitors").

Depending on your foregoing role, this Privacy Policy will apply to you differently and sets out our practices for collecting, using, maintaining, protecting, and disclosing that information, as well as your rights in determining what we do with the information that we collect and hold about you, and how you can contact us to update your contact information or get answers to questions you may have about our privacy practices.

You are not legally required to provide us with any Personal Data. If you do not wish to provide us with your Personal Data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with the Website, or use of the Services.

The Services are designed for businesses and are not intended for personal or household use. Accordingly, we treat all Personal Data covered by this Privacy Policy, including information about any Website Visitors, as pertaining to individuals acting as business representatives, rather than in their personal capacity.

Personal Data 

In order to provide the Services to our Customers, we collect and process certain information (which may include Personal Data) about our Customer's Authorized Representatives and End Users. We also collect Personal Data when Website Visitors visit our Website.

We may collect, or process on behalf of our Customers, the following categories of Personal Data when you use the Services or Website:

‍Account Information: Information associated with an account to which the Services are provided, which may include Authorized Representative name, contact information, account ID, billing information, and account plan information.

• Profile and End User Information: Information associated with the Strigo profile of an End User who uses the Services under a validly registered account or that is provided by the End User joining an event, which may include name, display name, picture, email address, phone number, job information, stated locale, user ID, or other information provided by the End User or their account owner.
• Contacts and Calendar Integrations: Contact information added by Authorized Representatives or their End Users to create contact lists on Strigo, which may include contact information an End User integrates from a third-party app. End users can also integrate their calendars from other services with their Strigo profile or account.
• Settings: Information associated with the preferences and settings on the Authorized Representative or End User profile, which may include audio and video settings, recording file location, screen sharing settings, and other settings and configuration information.
• Registration Information: Information people provide when registering for certain Services, which may include name and contact information, responses to registration questions, and other registration information requested.
• Device Information: Information about the computers, phones, and other devices people use when interacting with Strigo or using the Services, which may include information about the trainers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
• Content and Context: hosted in the framework of the Services, which may include audio, video, in-meeting messages, chat messaging content, transcriptions, written feedback, responses to polls and Q&A, and files, as well as related context, such as invitation details, meeting or chat name, or meeting agenda. Content may contain your voice and image, depending on the Authorized Representative's settings, what you choose to share your settings, and what you do in the framework of your use of the Services.
• Services and Website Usage: Information about how people and their devices interact with Strigo or in the framework of their use of the Services, such as: whether End Userssent messages and who they message with; performance data; mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off), and other End User inputs that help Strigo to understand feature usage, improve product design, and suggest features; which third-party apps users add to a meeting and what information and actions the app is authorized to access and perform; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with the Website, including what pages they accessed, their interaction with the Website features, and whether or not they signed up for a Strigo subscription.
• Communications with Strigo: Information about your communications with Strigo, including relating to support questions, your account, and other inquiries.
• Information from Partners: Strigo obtains information about Authorized Users and their End Users from third-party companies, such as market data enrichment services, including information about an account owner's company size or industry, contact information, or activity of certain enterprise domains.

How We May Use Your Personal Data

We may use your Personal Data as necessary for the performance of the Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving the Services, e.g. in understanding how the Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling the Services; providing Customer service and technical support; and protecting and securing our Customers, users, visitors, prospects, ourselves and the Services. 

If you reside or are using the Website or Services in a territory governed by privacy laws under which "consent” is the only or most appropriate legal basis for the processing of Personal Data as described herein, your acceptance of our Terms of Service and this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@strigo.io.

Specifically, we may use your Personal Data for the following purposes:

• To facilitate, operate, enhance and provide the Services;
• To train our Customer and its Authorized Representatives;
• To provide our Customers and their Authorized Representatives with assistance and support;
• To gain a better understanding on how individuals use and interact with the Website and the Services, and how we could improve their and others' user experience, and continue improving our products, offerings and the overall performance of the Services;
• To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using the Services, and thereby increase your engagement and overall satisfaction with the Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
• To contact our Customers with general or personalized service-relate messages, as well as promotional messages that may be of specific interest to them;
• To facilitate, sponsor and offer certain events, contests and promotions;
• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity; 
• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal prohibited activity;
• To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and 
• To comply, and maintain our compliance, with applicable laws, regulations and standards.

Personal Data Location

We and our authorized Service Providers maintain, store and process Personal Data in the United States, Europe, Australia, Singapore and other locations, as reasonably necessary for the proper performance and delivery of the Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Strigo is committed to protecting Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction. To the extent we transfer Customers' personal data from the EEA, Switzerland or the United Kingdom, we rely on appropriate data transfer mechanisms and safeguards as established under applicable law, such as the Standard Contractual Clauses (EEA).  

Data Protection in Israel: Strigo Ltd. is headquartered in Israel, a jurisdiction which is considered by the European Commission and the UK Information Commissioner's Office to be offering an adequate level of protection for the Personal Data of EU Member State and UK residents.

How We Share Your Personal Data

We may share Personal Data with:

• Our Service Providers acting on our behalf.
• Our Customers.
• Third parties for legal compliance, or other lawful purposes.
• Strigo's Subsidiaries and third parties in the event of a sale or transfer of our business or assets.

We do not share or otherwise disclose Personal Data we collect about you, except as described in this Privacy Notice or otherwise disclosed to you at the time the data is collected. Additionally, we do not sell the Personal Data we collect about you, as defined by the California Consumer Privacy Act (CCPA).

Service Providers. We may engage selected third party companies and individuals to perform services complimentary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer management systems , and our legal, financial and compliance advisors (collectively, "Service Providers”). Our Service Providers may have access to Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing the Services, and may only use such data for such limited purposes as determined in our agreements with them.  

Our Customers. Our Customers have access to any data we process on their behalf in our capacity as "processor” or a "service provider”.

Legal Compliance. We also may disclose data about you: (i) if we are required to do so by law or legal process, (ii) in response to a request from a court, law enforcement authorities, or government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity

Strigo's Subsidiaries and Affiliated Companies; Sale or Transfer of Our Business. We may share Personal Data internally within our group, for the purposes described in this Privacy Policy. In addition, we reserve the right to transfer Personal Data we have about you in the event we should undergo any sale or transfer of our business or change in control, including by means of merger, acquisition or purchase of substantially all or part of our assets. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Data with any inquiries concerning the processing of that information.

Your Rights and Choices

Subject to applicable law(s), you have the right to:

• Access your Personal Data, rectify it, restrict its processing, or request its deletion.
• Receive the Personal Data you provided to us to transmit it to another company.
• Withdraw any consent provided.
• Where applicable, lodge a complaint with your supervisory authority.

Subject to applicable law(s), you have certain rights regarding the Personal Data we maintain about you and certain choices about what Personal Data we collect from you, how we use it, and how we communicate with you. Those include your rights to:

• Request access to and receive information about the Personal Data we maintain about you, to update and correct inaccuracies in your Personal Data, to restrict the processing of your Personal Data, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• Withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

Additionally, if you are located in California, we will not deny, charge different prices for, or provide a different level of quality of services if you choose to exercise these rights, except where the different price or level of quality of services is reasonably related to the value of the data that we receive from you. In some instances, we may not be able to provide you with the services that you request if you choose to exercise certain rights.

If you are located in California, you may also choose to exercise the following right(s):

• Not to provide Personal Data to Strigo by refraining from submitting Personal Data directly to us. If you do not provide Personal Data, you may not be able to benefit from the full range of the Services, and we may not be able to provide you with the Services if that information is necessary to provide you with them, or if we are legally or contractually required to collect it in relation to the provision of such Services.
• To opt out of the collection and use of certain information, which we collect about you by automated means, when you visit our websites or use our apps. Your browser may tell you how to be notified of and opt out of having certain types of cookies placed on your device. Note that without certain cookies you may not be able to use all of the features of the Website or Services. 
• To opt out of certain uses of information, which we collect about you by automated means when you visit third-party websites and interact with our ads. We may use Service Providers to serve ads on those third-party websites. These ads may be customized and served based on the use of data we and our partners have collected on the Website. In addition, some of our Service Providers and partners may collect information about your online activities over time and across third-party websites to customize and serve these ads. 
• To tell us not to send you marketing emails by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below.

The above rights may be limited in some circumstances by local law requirements.

Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data may then be retained by us for legal purposes (e.g., as evidence of the identity of the person submitting the request). In addition, we may redact from the data which we will make available to you, any Personal Data related to others.

Data Retention

We retain Customer Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with the Services, the Website and the offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

Data Security

We implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, although we make efforts to protect your privacy, we cannot guarantee that the Website or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. 

To learn more, please visit https://strigo.io/security.

Cookies and Tracking Technologies

We and our Service Providers use cookies, beacons, pixels, tags and scripts. These technologies are used in order to provide, maintain, and  improve the Website and Services, to optimize our offerings and marketing activities,  and to provide you with a better experience (for example, in order  to track users' preferences, to better secure our Services, to identify technical issues, and to monitor and  improve the overall performance of our Services). 

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the "Session Cookies". Some last for longer periods and are called "Persistent Cookies”. We use both types.

We use Persistent Cookies to remember your log-in details and make it easier for you to log-in details and make it easier for you to log-in the next time you access the Strigo platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services' features and tools. We may also use HTML5 local storage or Flash cookies for the above mentioned purposes. These technologies differ from browser in the amount and type of data they store, and how they store it.

Whilst we do not change our practices in response to a "Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings.  Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.  

We also use web analytics tools, including Google Analytics, Segment, Intercom and FullStory. These tools help us understand users' behavior on the Website and the Strigo platform, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. 

Communications

We engage in service and promotional communications, through e-mail, phone and notifications. 

We may contact you with important information regarding the Services. For example, we may send you notifications of changes or updates to the Services, billing issues, service changes, log-in attempts or password reset notices, etc. If you are registered as a user of the Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to pot out of receiving certain service communications which are integral to your use (like password resets or billing notices). 

We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our customer, user or prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, Website, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Strigo at any time by sending an email to: privacy@strigo.io, changing your communications preferences in your profile settings whilst being logged as a user of the Services, or by following the "unsubscribe”, "opt-out” or "change e-mail preferences” instructions contained in the promotional communications you receive.

Privacy of Children

Strigo's products and services are not directed to or intended for children.

Strigo does not offer services to minors and does not knowingly collect Personal Data from children under the age of 13. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please notify us using our contact details below.

Processing on behalf of Customers

Our processing of Personal Data on behalf of our Customers as part of the Services is governed by our agreements with such Customers. We process this data on behalf of our Customers in our capacity as service providers (or "data processors”) to our Customers. Our Customers are "data controllers” (under the EU or UK GDPR and similar laws) or "business” (under the CCPA or similar laws) with respect to that data. 

Our Customers are solely responsible for determining whether and how they wish to use the Services, and for ensuring that all individuals using Strigo on the Customers' behalf or at their request have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through the Services are fully met by the Customers, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the Services. 

Third party websites

Users may find advertising or other content on the Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from the Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to the Site, is subject to that website's own terms and policies.

Changes to this privacy policy

Strigo has the discretion to update this Privacy Policy at any time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the the amended version of the policy on the Website and/or Services. If we make changes that we believe materially alter your privacy rights, Strigo will provide prior notice, such as via email or through the Website. After such notice period, all amendments shall be deemed accepted by you. 

Contacting us

If you have any questions or comments about our Privacy Policy, or if you have any concerns regarding your Personal Data held with us, please contact privacy@strigo.io or our Data Protection Officer (DPO) at dpo@strigo.io. You may also contact us if you wish to exercise your privacy rights under any law which applies to you, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), or the Virginia Consumer Data Protection Act (VCDPA).If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable

EU and UK Representative: We have appointed Prighter as our privacy representative and your point of contact for data protection matters pursuant to Article 27 of the EU GDPR and the UK GDPR (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/13408361670.