Remoty Privacy Policy

We, at Remoty Visual Ltd., are committed to respecting our User’s privacy, to protecting their Personal Data and to making sure it is used properly by us.

The purpose of this Privacy Policy is to ensure you are fully informed and aware as to the scope, nature and types of Information REMOTY collects and/or otherwise receives from or about you (or about other Individuals) while the App is installed and activated on your mobile device, for the execution of the Purpose detailed in the T&C, how is it being Processed, what is legal basis for Processing, what we may use it for, who we may share it with, what kind of technologies we use in the App for the collection of Personal Data and Non-Personal Data, what our retention periods are, and what are your rights in relation to the Personal Data we Process. For further details, please read our full Privacy Policy below.

Terms which are defined in this Privacy Policy shall have the same meaning ascribed to them in the App’s Terms and Conditions, which can be viewed at www.remoty.com/terms (above and hereinafter: the “T&C), unless otherwise defined herein.

 

FULL PRIVACY POLICY

  1. PREAMBLE AND DEFINITIONS
    • Remoty Visual Ltd. (“REMOTY”, “we”, “our” or “us”) provides this full privacy policy, as may be updated from time to time according to the terms set forth herein (our “Policy” or “Privacy Policy”), to inform You of our policies and procedures regarding the way we Process Information when you Use our App.
    • Following your first download and installation of the App on your mobile device, you will be asked to indicate that you have read and hereby agree to be bound by this Privacy Policy. Please read carefully the terms of this Privacy Policy. If you have further questions or concerns regarding this Privacy Policy, please contact us at: privacy@remoty.com.
    • Definitions:
      • The terms “App“, “Call-Session“, “Challenge“, “Challenge Fee“, “Challenge Related Information”, Helper“, “Helpee“, “Expert”, “Individual“, “Governing Law“, “User Account” and “you” shall have the same meaning ascribed to them in the T&C.
      • Controller“, “Processor” and “Consent” – shall have the meaning ascribed to it under the GDPR.
      • GDPR” – means the General Data Protection Regulation (EU) 2016/679, as amended from time to time.
      • Information” – means Challenge Related Information, Non-PII and PII, all together.
      • Personal Data” or “PII” – means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
      • Process” – means any operation or set of operations which is performed by REMOTY (and/or by any third party’s acting on its behalf) on User (or other Individual) Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
      • “Non – Personal Data” or “Non-PII” – means any information, data or content, in any format or media, which is anonymous and/or does not personally identify an Individual and/or reveal an Individual’s specific identity and/or cannot be attributed to an Individual, all, in whatever form is collected and/or received in or as a result of a Call-Session and/or due to a User’s Use of the App.

 

  1. WHEN DOES THIS PRIVACY POLICY APPLY
    • This Privacy Policy applies to the Processing of User’s Personal Data by REMOTY, whether such User is an Expert, Helper or Helpee, in its relationship with us when it Uses the App for the Purposes defined in the T&C, and as further detailed under this Privacy Policy. To the extent the User is an Expert, other terms may apply, as detailed in the T&C.
    • Please note that this Privacy Policy does not apply to any service provided by an Expert/Helper to Helpee and/or any other interaction between Expert/Helper and Helpee outside the scope of the App, which may be subject to separate terms (including separate privacy policies).
    • For the purpose of this Privacy Policy, whenever reference is made to a Helper, it shall apply equally to an Expert regarding the services provided by the Expert to the Helpee, in the required changes, all, without derogating from any other terms which may apply in the relations between an Expert and Helpee according to the T&C.

 

  1. THE TYPES OF PERSONAL DATA YOU PROVIDE
    • When you first download the App, you will be asked to provide some informative details about yourself in order to create your User Account and be able to use the App. Such informative details may inter alia include some Personal Data, as detailed below (and may be updated from time to time):
      • If You are a Helper/Expert, your Personal Data in your User Account may include basic contact details (such as your email address, full name, password, and optionally your Facebook id);
      • If You are a Helpee, your Personal Data in your User Account may include: Basic contact details (such as your email address, full name, password, and optionally your Facebook id).
    • During your Use of the App, you may provide and/or otherwise upload to the App additional Personal Data:
  • If you are an Expert/Helper –
    • your Personal Data may include any information you choose to transfer, disclose, and/or otherwise reveal in a Call-Session with a Helpee, regarding your or other Individual’s private affairs and/or which can personally identify you or an Individual and/or otherwise can be attributed to you or other Individual.
    • Written Call-Session summary submitted by you (which may include Personal Data, to the extent you chose to disclose such data in your summary).
  • If You are a Helpee –
    • Your Personal Data may include any information you choose to transfer, disclose, reveal and/or otherwise visualize in a Call-Session with a Helper, regarding your or other Individual’s private affairs and/or which can personally identify you or an Individual and/or otherwise can be attributed to you or other Individual;
    • Payments information (such as Helpee’s credit card number – to the extent Helpee chooses to use the Expert’s option (as detailed in the T&C). Such Information will be stored at REMOTY’S third party’s payments supplier. For more details, please see Section ‎10 below.
    • Written Call-Session summary submitted by you (which may include Personal Data, to the extent you chose to disclose such data in your summary).
  • You may choose not to provide us with certain Personal Data. However, to the extent such Personal Data is necessary for the creation of your User Account or for providing you with the services via the App (such as when you choose to use the Expert’s option), such decision may limit your ability to use the App (whether in whole or in parts). For more information about your rights, please see section ‎12 below.

 

  1. THE TYPES OF PERSONAL DATA WE COLLECT OR GENERATE
    • In addition to the Personal Data you provide us (as an Expert/Helper or Helpee) when you use the App, we may also collect or generate Personal Data about you and/or your use of the App, and Process it according to the terms herein. The Process of PII by REMOTY (including via the App) commences on your first download and installation of the App on your mobile device (whether you do it as Expert/Helper and/or Helpee).
    • The types of Personal Data we collect or generate from your Use of the App and/or otherwise receive from third parties (as may be updated from time to time):
      • Personal Data incorporated in a Challenge Related Information (such as User’s text messages, snapshot image of Helpee’s surroundings, video recording of Helpee’s surroundings, User’s (and/or other Individual’s) voice recording) and/or video recording of the Call- Session;
      • User’s broad location (as indicated by its network connection);
      • Helpee’s rating on Helper’s performance in solving the Challenge;
      • User’s engagement with our App, such as which App buttons are tapped by the User.
      • Written Call-Session summary submitted by the User, and transcoding text of a Call-Session, which is based on the Call-Session recording (based on each Call-Session, such transcoding text may include Personal Data).

 

  1. HOW WE USE YOUR PERSONAL DATA
    We will store, use and/or otherwise Process your Personal Data for one or more purposes, for the following purposes as set forth below:

    • To complete User registration to the App (and creating User Account), and identify User  when re-enters the App;
    • To communicate with the User, personalize User’s experience with the App, better understand User’s needs and obtain its feedback regarding the App and User’s experience;
    • To provide User with service announcements and further administrative information regarding User’s use of the App;
    • To transfer User’s Personal Data to third party vendors, service providers, contractors who are working on REMOTY’s behalf for storage, hosting, Process and/or back up purposes, or, transfer certain User’s Personal Data to Hands-On Assistance, to the extent requested by Helpee according to the T&Cs;
    • To collect payment from Helpee (to the extent choose the Expert option in the App).
    • To enable User to the use the App (and the services offered via the App) for the Purpose;
    • For monitoring and supervision purpose of Users’ interaction in a Call-Session, including (to the extent required) for dispute resolution between Helpee and Helper/Expert regarding the a specific Challenge;
    • To protect the Platforms,  as detailed in the T&C;
    • To enforce the T&C and this Privacy Policy), and any other REMOTY’s internal policies and procedures;
    • For statistical monitoring and analysis on an aggregated basis in order to improve our App;
    • For on-going adaptation and secure REMOTY’s systems against current and future attacks;
    • To comply with and in order to asses compliance with applicable laws, rules and regulations.

 

  1. HOW WE COLLECT PERSONAL DATA
    We may collect and/or generate Personal Data from various sources:

    • From you – when you submit, upload and/or otherwise provide us with your Personal Data when you Use the App, when you allow us to have access to certain tools which are installed in your mobile device (such as your mobile device microphone, camera);
    • From third parties which provide us Personal Data about you and/or about your use of the App. In order to do so, we may use tools which record the video and/or audio of a Call-Session and/or the way a User is using the App, and its interaction with other User who is the recipient of the Call-Session;

 

  1. LEGAL BASIS FOR PROCESSING
    We obligate not to Process your Personal Data, unless there is a lawful basis for such Process. The lawful basis for our Process activities that are detailed in Section ‎5 are as follows:

    • Processing is necessary in order to perform a contract to which you are a party to, or in order to take steps at your request prior to entering into a contract. This means, that we need to Process your Personal Data to enable you to Use the App, and be able to provide you with the services via the App (for example – create your User Account, bill you for a successful Challenge (to the extent Helpee choose the Expert’s option), send you informative and operational notices, disputes resolutions between Helpee and Helper/Experts regarding to a specific Challenge, to assist you if you encounter any problem in the operation of the App, etc.);
    • You Consented to REMOTY’s Processing of your Personal Data for one or more specific purpose: For example, if you Consented to our usage of recording technologies tools to help us improve our App and/or the services provided by the App, for statistical analytics and reports. You can withdraw your Consent for our usage of recoding tool for the Processing activity detailed in this section (by opting-out and sending e-mail to: privacy@remoty.com). You will still be able to use the App if you opt-out, but disabling such tools may affect your use experience. Please note that we will still be able to use such tools for other purposes – to the extent we use such tools for other legal basis for Processing, as detailed in Section ‎7;
    • Processing is necessary for compliance with a legal obligation to which the REMOTY is subject to (for example – the Platform’s policies).

 

  1. NON-PERSONAL DATA
    • Collection of Non-Personal Data. Further to the collection of Personal Data, we may also collect and/or generate and/or otherwise Process Non-Personal Data, such as:
      • User’s technical device details (such as device model, operating system version);
      • User’s interaction history (i.e. list of past Call-Sessions, including their durations and Call-Session date, without any Personal Data incorporated therein);
      • User’s Mobile push token, “Facebook” access token) meaning we collect an identifier that allows Us to send you notifications about your interaction with other Users (when applicable);
      • The Challenge category, and whether the Challenge was solved.
    • How We collect Non-Personal Data. We may use the recording tool technology (as detailed in section ‎7.2 above) for the collection of Non-PII.
    • How We use Non-PII. The aforementioned tools allows us to Process the NON-PII for the following purposes: (i) monitor and analyze User’s use of the App and, if required, for the technical administration and troubleshooting of the App; (ii) for commercial research and further development; (iii) improving the App by creating system analytics and statistical data; (iv) transfer to third party who are working on our behalf; and (v) for any other legitimate purpose. You hereby warrant and represent that you will not have claim and/or demand, from any kind, regarding the use of the Non-PII any legitimate purpose.
    • It is hereby clarified that if and to the extent any Non-PII detailed under sections ‎8.1.1 – ‎8.1.6 above, or, to the extent any of the technologies collect and/or otherwise generate Personal Data for the purpose detailed under Section ‎8.3 above, We will not use it without receiving your opt-in Consent and/or other have lawful basis for such Process activity.

 

  1. CHALLENGE RELATED INFORMATION. Any PII and/or Non-PII included in the Challenge Related Information will be Processed by REMOTY according to the relevant parts under this Privacy Policy.

 

  1.   DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
    As part of the Process activity and in connection with the Purposes set forth in the T&C’s (as further detailed in this Privacy Policy), we may share, disclose and/or otherwise transfer the Information to third parties, for the following purpose:

    • With third party’s service providers (such as cloud service providers, subcontractors, consultants) which assist us in the operation and the on-going activity of the App, as detailed in Section ‎0 above. These third parties will be subject to appropriate data protection obligations, and they will use the Information as described under this Privacy Policy.
    • Helpee’s Personal Data will be transferred to Expert and/or Hands-On Assistance, to the extent Expert  and or Hands-On service was required by the Helpee,
    • To the extent required in order to comply with any applicable law, regulations or legal requests and assist law enforcement agencies. We may further disclose Information believe in good faith that disclosure of Information is necessary to prevent imminent physical harm, financial loss or to report suspected illegal activity. In all cases, such Information will only be disclosed in accordance with applicable laws and regulations;
    • To take any action in any case of dispute involving you with respect to your usage of our App; and
    • In connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

 

  1. INTERNATION TRANSFER OF PERSONAL DATA
    • Disclosure, share or transfer of the Information under Section ‎10 above can be on a global basis, in some cases outside your state. When we transfer Personal Data outside the EEA, we ensure that it is protected in a manner consistent with the GDPR (for example, the country we send the Information was approved by the European Committee as providing adequate level of protection to Personal Data (such as Israel); or the recipient signed a contract based on the “standard contractual clauses” approved by the European Committee; or the recipient is located in the US and is certified by the EU-US Privacy Shield, or other circumstances the law permits us to transfer your Personal Data outside the European Union.
    • For more information about the transfer of your Personal Data outside the EEA, you can contact us at: privacy@remoty.com.

 

  1. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA.
    • We respect your rights regarding your Personal Data, and therefore taking the steps necessary to enable you the rights to access,  following rights:
      • Right to access: You can ask us for confirmation on whether your Personal Data is being Processed, ask us to provide you with further details on how we Process your Personal Data and receive a copy of the PII we hold about you. Before disclosing you with any information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law.
      • Right to rectification: You can ask us to update any inaccuracies in your Personal Data that we hold. Without derogating from the foregoing, please note that you can easily rectify your Personal Data in your User Account.
      • Right to erasure (the right to be forgotten): You can ask us to erase your Personal in certain circumstances (such as if we no longer have lawful basis to use such Personal Data, or if it is no longer necessary for the Purposes, etc.). Please note that this right only apply to Personal Data which we are not legally entitled to retain.  Further, please note that deleting all your Personal Data from your User Account means that you can no longer use any of your User Account, your Personal Data will be permanently deleted, and REMOTY will not be able to restore your User Account or retrieve your data in the future. If you contact REMOTY in the future, the system will not recognize your User Account and you will need to create new User Account
      • Right to Restriction of Processing: You can restrict how we use you Personal Data in certain circumstances (such as if we no longer need the Personal Data for the Purposes). Please note that this right will only apply to the extent we are not legally entitled to refuse such request.
      • Right of Data Portability: You can ask us to transmit the Personal Data you have provided to us to a third party, under the circumstance covered under the GDPR.
      • Right to Lodge a Complaint: You can raise a complaint about our Processing, if you think that any of your rights have been infringed by us, with the data protection regulator in your jurisdiction, but we recommend you contact us first – and we will do our best to solve any complaint.
      • Right to Withdrawal Consent: Where our Processing is based on your Consent, you can withdraw your Consent to Processing so that we stop that particular Processing. You can withdraw your Consent by sending e-mail to: privacy@remoty.com.
    • We obligate to make all reasonable efforts to respect your request as soon as practically possible (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.

 

  1. RETENTION PERIOD
    • We will retain your Personal Data information for as long as is necessary for the Purposes for which they were collected and any other permitted linked purposes. So if Personal Data is used for two Purposes, we will retain it until the purpose with the longest retention period expires; but we will stop using it for the Purpose with a shorter retention period once that shorter period has expired.
    • Unless otherwise restricted under applicable law, Non-Personal Data will be retained indefinitely.

 

  1. YOUR REPRESENTATIONS. 

BY USING THE APP, YOU HEREBY CONFIRM THAT YOU RECEIVED ALL APPLICABLE CONSENTS REQUIRED UNDER APPLICABLE LAW, FROM EACH AND ANY THIRD PARTY (INCLUDING ANY INDIVIDUAL) SURROUNDING YOU WHILE THE APP IS ACTIVATED, FOR THE RECEIPT, COLLECTION, PROCESS AND USE OF THE PII BY REMOTY (INCLUDING SERVICE PROVIDERS ACTING ON REMOTY’S BEHALF) ACCORDING TO THE TERMS OF THIS PRIVACY POLICY.

 

  1. SECURITY MEASURES.
    • We take the safeguarding of the Information very seriously, and use a variety of methods to try to protect the Information from loss or unauthorized use or access when it is in our possession or control, including reasonable technical and organizational measures which restrict access to the Information. However, we do not promise that any Information will be fully protected from unauthorized disclosure or use.
    • Please note that REMOTY does not check the validity of the use of your email and password, and any User of the App with your email and password will be considered as your User of the App. You should take steps to protect your mobile device (including any personal and/or confidential and/or sensitive information contained in it, including any PII incorporated in the User’s Account) and/or the confidentiality of any content, information or data where the App is activated and/or the privacy of any Individuals surrounding You while the App is activated.

 

  1. OUR POLICY TOWARDS CHILDREN

Our App is not meant to be used by or for persons under 18, as such, we do not knowingly collect Personal Data from minors younger than 18. Insofar as Personal Data may be collected based on your Consent, the Data Subject must be above the age of 16 (or above the age of 13 if this is the legal requirement in your country). If these age requirements are not met, you are required to obtain the Consent of the parent or guardian to provide and process information in accordance with this Policy; lacking such Consent will not allow you to Use the App.

 

  1. CHANGES TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy at our sole discretion and/or at the respective Platform’s request. We will inform you of any such change by posting a notice in the “What’s new” section in the Platforms, and also upload a new/updated privacy policy. We will allow 7 days prior notice prior to such change; However, substantial changes will be effective thirty (30) days after the notice was initially posted. We will make an effort to inform you of substantial changes through the channels of communication generally used in such circumstances, and subject to the requirements of applicable laws – to obtain your Consent. If we need to adapt this Privacy Policy to legal requirements, the amended Privacy Policy will become effective immediately or as required.

 

  1. CONTACT US. If you have any concerns or questions about this Privacy Policy, please contact us at privacy@remoty.com.

 

Last Updated: July 25, 2018

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