Privacy policy

Last updated January 30, 2023

Thank you for choosing to be part of our community at Co-pilot CX Ltd., doing business as Copilot (“Copilot”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at hello@copilot.cx.

When you visit our website www.copilot.cx, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website (such as www.copilot.cx), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you choose to directly share with us, either by entering it on our website or providing it to us in any other way (such as when you contact us), including personal information such as your name, email address, phone number, company name, location and other information that identifies an individual personally, as well as information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use.

We also collect information automatically through the use of cookies and similar technologies, such as IP address and/or browser and device characteristics when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Please be aware that you are not legally required to provide us with any information and any information will be provided by you voluntarily and at your discretion. You may withdraw your consent to allow us to collect your information at any time. Please note however that withdrawing your consent will not affect the lawfulness of our processing of your information before its withdrawal.

 

2. HOW DO WE USE YOUR INFORMATION?

We use your information, including personal information, alone or in combination with other information that we may collect about you, including information from third parties, for the following purposes that we consider in our legitimate interests:

• To provide you with the Site and with our Services.
• To communicate with you (via email or other platforms), including responding to your requests or inquiries.
• To better understand how users access and use our Site, both on an aggregated and individualized basis.
• To identify and prevent unauthorized or prohibited uses of the Site, viruses, frauds or violation of our terms and conditions, this policy or any applicable law.
• To send you marketing communications including information on our products and services, if you gave your consent to the communication.
• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
• We may share your information in any case of dispute, or legal proceeding of any kind, between you and us concerning the Site or your use thereof.

When providing us with your Personal Information, you are also requested to define your marketing preference. Based on your marketing preferences we may[1]:

• Send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you provided to us for marketing purposes, if this is in accordance with your marketing preferences.
• Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
• Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.

You can opt-out of our marketing emails and update your marketing preference at any time.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to access, collect or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy[2]. We will not use cookies or similar tracking services without first obtaining your explicit consent.

If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY

We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in the United States, and other countries. If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. Where we transfer your personal information to countries and territories outside of the European Economic Area which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission and “adequacy regulations” from the Secretary of State in the United Kingdom (as applicable). Where the transfer is not subject to an adequacy decision or regulations, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law. The safeguards we use are the European Commission-approved standard contractual clauses, and other appropriate legal mechanisms.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through the implementation of appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at adaya@copilot.cx.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the European Economic Area or California), you have certain rights under applicable data protection laws, which may include the right to:

• Request access to and be provided with information on the processing of your personal information;
• Request corrections of your personal information if such personal information proves inaccurate or incomplete;

• Request your personal information to be deleted (i) if it is no longer necessary for the purposes described in this Policy, (ii) should you decide to withdraw your consent where you gave it, (iii) should you identify that it would have been unlawfully processed, or (iv) should we be under a legal obligation to erase it to comply with relevant legislation and always provided we are not under a legal obligation to keep it;
• Restrict the processing of your personal information (i) if you contest its accuracy; (ii) if the processing is unlawful and you oppose the erasure; (iii) if it is no longer needed for the purposes set out in this Policy but you require it for the establishment, exercise or defense of a legal claim, or (iv) if you object to profiling;
• Receive personal information which you provided to us in a structured, commonly used and machine-readable format and to transmit it to another provider provided it is processed based on your consent or our contract. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws; and
• File a complaint about our use of your personal information with the data privacy authority of the country in which you live - you can find their contact details here: http://ec.europa.eu/justice/da.... If you have a complaint about our data practices, we hope that you’ll reach out to us first, so we have a chance to address your concerns.

If you have any questions or comments about your privacy rights, you may email us at hello@copilot.cx.

10. DATA BREACH

A data breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. In the event that a data breach occurs, you will be notified if Co-pilot CX Ltd. believes you are likely to be at risk of serious harm as a result of such data breach. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Co-pilot CX Ltd. becomes aware of a data breach which has resulted or may result in unauthorized access, use or disclosure of personal information Co-pilot CX Ltd. will promptly investigate the matter and notify the applicable Supervisory Authority not later that 72 hours after having becoming aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we collected or disclosed to third parties for direct marketing purposes; the categories of sources of such information; the business or commercial purpose for collecting, selling, or sharing your personal information; the categories of third parties to whom we disclose or sell, or with whom we share, personal information; the categories of personal information we sell and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident, you may also request that we delete certain information, and correct inaccurate personal information, that we maintain about you. You also have the right to limit the use and disclosure of sensitive personal information collected about you. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of these rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Site or Service to you. If you ask us to delete it, you may no longer be able to access or use the Site or Service.

13. DO WE MAKE UPDATES TO THIS POLICY?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Elad Levi, by email at elad@copilot.cx, or by post to:

Co-pilot CX Ltd.

Elad Levi

2 Hashlosha st.

Tel Aviv, Israel

[1] This entire section should be part of the policy due to the fact that marketing preference option is mandatory - however they are currently missing this function.

[2] Currently on their website there is a clear indication that only Google Analytics is being used – this needs to be verified and either the policy or the cookies banner on the website updated.