Last Updated: April 21, 2019

This privacy policy (“Privacy Policy”) governs how we, Granulate Cloud Solutions Ltd. (together, “Granulate” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”, “you”) such as in the following use cases:

  • When you make use of, or interact with our platform (“Platform”)
    1. When you sign up for an account, login and purchase our services
    2. When you create administrators for your use of the Platform
    3. When your administrator user create users for your use of the Platform
    4. When you make use of the platform for its intended use (e.g., optimize cost, latency and/or throughput)
  • When you browse or visit our website, https://www.granulate.io/ (“Website”)
  • When you make use of, or interact with, our Website
    1. When you request a demo
    2. When you subscribe to the email list / newsletters / blog
    3. When you contact us (e.g. customer support, help, submit a request)
  • When you attend a marketing event and provide Personal Data
  • When you exchange business cards with us
  • When we acquire your Personal Data from third-party sources (such as lead-generation companies)
  • When we use the Personal Data of our service providers
  • When we use the Personal Data of our customers
  • When you interact with us on our social media profiles (e.g., Facebook, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. How we protect and store your personal data
  3. How we share your personal data
  4. Additional information regarding transfers of personal data
  5. Your rights
  6. Use by children
  7. How can I delete my account?
  8. Links to and interaction with third party product
  9. Log files
  10. Cookies and other tracking technologies
  11. Analytic tools
  12. California privacy rights
  13. Our California do not track notice
  14. Deletion of content from California residents
  15. How to contact us
  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data we collect

Why is the data
collected and for what purposes?

 

Legal basis (GDPR
only)

 

 

Third parties with
whom we share your data

 

 

Consequences of not
providing the data

 

 

When you make use of,
or interact with our Platform

When you
sign up for an account, login and purchase our services

·      Full name

·      Email address

·      Company address

·      Company name

·      Job position

·      Phone number

·      User name

·      Password

·      Payment methods

·      Usage patterns

· Any other data you decide to provide/supply

 

 

·        To create an account

 

·        To fulfill your requests for products and/or services and for related activities (e.g., account management, support and to provide
other services related to your relationship with Granulate)

 

·        To perform/execute the agreement

 

·        To grant you access to the services (our Platform)

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.

 

Legitimate interest
(e.g.
sign
up to the service)

 

3rd party
platforms such as

for the following
purposes:

·        AWS which provides storage and compute for our Back Office

 

 

Cannot create an
account

 

Cannot fulfill your
request for products and/or services

 

Cannot perform the
agreement

 

Cannot grant you
access to the services

 

 

· To send marketing communications.

 

Consent

Cannot send marketing
communications

When you
create administrators for your use of the Platform

·        Full name

·        Email address

·        Company address

·        Company name

·        Job position

·        Phone number

·        User name

·        Password

·        Payment methods

·        Usage patterns

·   Any other data you decide to provide/supply

 

 

 

·        To create administrator users for your use of the Platform

 

·        To perform/execute the agreement

 

·        To grant you and your admin users access to the services
(our Platform)

 

·        To fulfill your requests for products and/or services and
for related activities (e.g., administrator management, support and to
provide other services related to your relationship with Granulate).

 

 

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.

 

Legitimate interest
(e.g.
to
create administrator users).

 

 

3rd party
platforms such as

for the following purposes:

·        AWS which provides storage and compute for our Back Office

 

 

Cannot create administrator
users for your use of the Platform

 

Cannot perform the
agreement

 

Cannot grant your administrator
users access to the services

 

Cannot fulfill your
request for products and/or services

 

 

 

 

 

 

 

· To send marketing communications.

 

Consent

Cannot send marketing
communications

When your
administrator user create users for your use of the Platform

·        Full name

·        Email address

·        Company address

·        Company name

·        Job position

·        Phone number

·        User name

·        Password

·        Payment methods

·        Usage patterns

·   Any other data you decide to provide/supply

 

 

 

 

 

·        To create users for the use of the Platform

 

·        To perform/execute the agreement

 

·   To grant your users access to the services (our Platform)

 

·      Manage your everyday business needs (e.g., Platform
administration)

 

·     To fulfill your requests for products and/or services and
for related activities (e.g., users services, support and to provide other
services related to your relationship with Granulate).

 

 

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.

 

Legitimate interest
(e.g.
to
create users).

 

3rd party
platforms such as

for the following purposes:

·  AWS which provides storage and compute for our Back Office

 

Cannot create users for your
use of the Platform

 

Cannot perform the
agreement

 

Cannot grant your users
access to the services

 

Cannot manage your
everyday business needs

 

Cannot fulfill your
request for products and/or services

 

 

· To send marketing communications.

 

Consent

Cannot send marketing
communications

When you
make use of the platform for its intended use (e.g., to optimize cost,
latency and/or throughput)

When used in the cloud,
the VMs external IPs will be collected

 

 

 

 

 

 

·        To use of the Platform

 

·        To perform/execute the agreement

 

·       To evaluate the platform

 

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.

 

Legitimate interest
(e.g.
to
offer support and help in evaluation, upgrades etc.).

 

3rd party
platforms such as

for the following
purposes:

·  AWS which provides storage and compute for our Back Office

 

Cannot use the
platform

 

Cannot perform the
agreement

 

Cannot evaluate the
platform

 

 

 

 

 

· To send marketing communications

 

When you browse or
visit our Website

Cookies, analytic
tools and log files

 

 

 

·      To provide better service

· To provide relevant marketing materials

Consent

 

Legitimate interest
(e.g. essential cookies)

 

3rd party
platforms such as for the following purposes:

 

·       Hubspot to automate communications and provide analytics

 

 

 

Cannot provide better
service

 

Cannot provide relevant
marketing materials

When you
make use of, or interact with, our Website

When you
request a demo

·         Full name

·         Email address

·         Company name

·         Phone number

·        Organization name

·  Any other data you decide to provide/supply

 

 

·  To contact you and explain our product

·    To customize your experience

·    To send newsletters or other marketing communications

 

 

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.

 

Legitimate interest
(e.g. to provide a demo).

3rd party
platforms such as for the following purposes:

· Hubspot to automate communications and provide analytics

·   WordPress as our website hosting platform

 

 

 

Cannot provide a demo

 

Cannot customize your
experience

· To send marketing communications

 

Consent

Cannot send marketing
communications

When you sign up for
our newsletters / email list / blog

·                    Full name

·                    Email address

·                    Phone number

·                    Organization name

 

 

·        To add you to our mailing list

 

·        To send newsletters or other marketing communications.

Consent

 

Legitimate interest
(e.g. send you more information about Granulate)

 

3rd party
platforms such as for the following purposes:

·        Hubspot to automate emails and provide analytics on
communications

·   WordPress as our website hosting platform

 

 

Cannot add you to our
mailing list

 

Cannot send you
marketing communications

When you contact us
(e.g. contact sales, customer support, help, submit a request)

·        Full name

·        Email address

·        Company name

·        Phone number

·  Any other data you decide to provide/supply

 

 

 

·  To process and answer questions

· To provide support (e.g., to solve problems, bugs or issues)

·  To customize your experience

 

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

 

Legitimate interest
(e.g. respond to a query sent by you)

3rd party
platforms such as for the following purposes:

 

· Hubspot to automate communications and provide analytics

·     WordPress as our website hosting platform

 

 

 

 

 

Cannot assist you and
respond your query

 

Cannot provide support

 

Cannot customize your
experience

· To send marketing communications

 

Consent

Cannot send marketing
communications

When you attend a
marketing event and provide Personal Data

·  Full name

·  Email address

·  Company name

·  Job position

·  Phone numbers

· Any other data you decide to provide/supply

 

 

·  To establish a business connection

· To send marketing communications

 

 

 

Consent

 

Legitimate interest
(e.g. send you more information about Granulate)

 

3rd party
platforms such as for the following purposes:

 

· Hubspot to automate communications and provide analytics

 

 

 

Cannot establish a
business connection

 

Cannot send marketing
communications

When you exchange
business cards with us

·  Full name

·  Email address

·  Company name

· Job position

· Phone numbers

· Any other data you decide to provide/supply

 

 

·  To establish a business connection

· To send marketing communications

 

 

Consent

 

Legitimate interest
(e.g. send you more information about Granulate)

 

3rd party
platforms such as for the following purposes:

 

· Hubspot to automate communications and provide analytics

 

Cannot establish a
business connection

 

Cannot send marketing
communications

When we acquire your
Personal Data from third-party sources (such as lead-generation companies)

· Full name

· Email address

· Company name

· Job position

· Phone numbers

· Any other data you decide to provide/supply

 

 

 

·  To establish a business connection

·        To send newsletters or other marketing communications

 

 

Depending on the context,
legitimate interest (B2B marketing), pre-contractual discussions or consent

 

3rd party
platforms such as for the following purposes:

 

·        Hubspot CRM as our tool for customer and lead  management

 

 

Cannot establish a
business connection

 

Cannot send marketing
communications

When we use the
Personal Data of our service providers and suppliers

· Full name

· Email address

· Company name

· Job position

· Phone number

· Any other data you decide to provide/supply

 

· To contact our service providers

 

· To perform the applicable agreement

 

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.

 

Legitimate interest
(e.g. perform the contract, send contract-related communications)

 

3rd party
platforms such as for the following purposes:

· Hubspot to automate communications and provide analytics

 

 

Cannot communicate
with you

 

Cannot perform the
applicable agreement

 

When we use the
Personal Data of our customers

·    Full name

·     Email address

·     Company name

·     Job position

·     Phone number

· Any other data you decide to provide/supply

 

·    To provide our products and services

 

·  To perform the applicable agreement

 

 

 

Processing is necessary
for the performance of a contract to which our customer is a party.

 

Compliance with a
legal obligation (e.g. tax laws, bookkeeping laws, etc.).

 

Legitimate interest
(e.g. send you contract-related communications)

 

3rd party
platforms such as for the following purposes:

·       AWS which provides storage and compute for our Back Office

·      Hubspot CRM as our tool for customer and lead management

·  WordPress as our website hosting platform

 

 

Cannot provide the
services and/or our products

 

Cannot perform the
agreement

 

Cannot communicate
with you

 

When you interact with
us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

·     Full name

·     Email address 

·     Company name

·     Job position

·     Social media handle

· Any other data you decide to provide/supply

 

· To reply and/or respond to your request or question

· To establish a first business connection/discussion

· To provide better service

 

 

Consent

 

Legitimate interest
(e.g. send you more information about Granulate)

3rd party
platforms such as for the following purposes:

·       Hubspot CRM as our tool for customer and lead  management

 

 

Cannot reply or
respond to your request

 

Cannot establish a
business connection

 

      

 

Finally, please note that some of the abovementioned Personal Data will be used for fraud detection and prevention, and for security purposes.

  1. 2. PERIOD OF STORAGE OF COLLECTED INFORMATION

Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request.  Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookies policy.

 
  1. HOW WE PROTECT AND STORE YOUR INFORMATION
    • Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to 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.
      • Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data 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, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
 
      1. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described in Section 1, we may share your information as follows:

      • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
      • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. 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 or assign Personal Data in connection with the foregoing events.
      • Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
      • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

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

 
      1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA 

Storage: AWS US-Virginia, subject to a privacy shield

Access from Israel: Access from Israel (e.g. by our staff located in Israel) is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

External transfers:

      • Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
      • Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.
      • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
 
    1.  
      1. YOUR RIGHTS

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 the GDPR):

      • You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
      • You have the right to request that we rectify any Personal Data we hold that it is inaccurate or misleading;
      • You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
      • The right to object, to or to request restriction, of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
      • The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
      • You have the right to object to profiling;
      • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;
      • The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
      • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us at privacy@granulate.io. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly 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 your identity and for security purposes, before disclosing the Personal Data requested to you. 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.

 
      1. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under 18, you shall not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children

 
      1. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing support@granulate.io. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

 
      1. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Website enables you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and 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 Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

 
      1. LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

 
      1. COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Website utilizes “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Website and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

 
      1. ANALYTIC TOOLS
      • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about 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 personally identifiable information. 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 http://www.google.com/analytics/terms/us.html/, 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/.
      • Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.
      • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, 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 and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices ohttp://www.youronlinechoices.eu/.
 
      1. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@granulate.io. Please note that we are only required to respond to one request per customer each year.

 
      1. OUR CALIFORNIA DO NOT TRACK NOTICE

We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

 
      1. DELETION OF CONTENT FROM CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Data you have publicly posted. To remove, please send an email to privacy@granulate.io. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

  
      1. 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@granulate.io.