DATA CONTROLLER AND DATA PROCESSOR

The Business is the data controller of the Users’ personal information.

SOLO Wellbeing is the data processor of the personal information.

Each Business is the data controller of its Users’ personal information. It determines the purposes and means for processing that data.

SOLO Wellbeing is the data processor of Users’ personal information. We only process Users’ personal information based on the Business’s instructions and for the purpose of providing the Service to them and the Users.

PERSONAL DATA BEING PROCESSED

IN GENERAL TERMS

We collect the following information from Users that use our Services. This is also the information we have collected in the past 12 months.

Categories of Personal Information Specific Types of Personal Information Collected

Identifiers full name, email address, account username.

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual and other information you provide when you interact with us.

Internet or other electronic network activity information Your browser type, operating system, IP address, domain name, number of times you used the Technology, dates you visited the Dashboard, error codes generated while your device is in contact with our Technology and the amount of time you spent using the Dashboard

We collect and process your contact information when you register to our Dashboard.

When registering to the Dashboard, you will be asked to provide information such as your email address, account username and password.

We refer to this entire data as “Contact Information”.

We collect and process information regarding your usage of the Technology 

The Technology also collect and processes personal data regarding the usage behavior and usage patterns in relation to the Technology, such as your current mood while using the Technology. In particular,  we collect your emotional score while using the technology and create data based on this usage for your business usage.

We refer to this overall data as “Usage Information”.

We collect analytics information about your use of the Dashboard. 

When you visit the Dashboard, we record and collect certain information about your interaction with the Dashboard. This includes the User’s IP address and approximate location derived from the IP address, domain name, time and date of access, type of browser used, language used, links clicked, and actions taken while using the Dashboard (“Analytics Information“).

You do not have a legal obligation to provide us with your Contact Information or Usage Information. However, if you choose to not share this information with us, we may not be able to provide you the Service.

HOW WE PROCESS PERSONAL DATA

To provide you with the Service.

We process your Contact and Usage Information in order to identify you and provide you with the Service and tailor its performances to your needs. (e.g. create an average emotional score for your personal usage).

We will use your Analytics Information for enhancing and developing the Technology.

SOLO Wellbeing will use the Analytics Information for its quality assurance and for development and enhancement of the Technology. We will use the Analytics Information collected via our Dashboard to improve the Dashboard and our email communications. We also use the Analytical Information to adapt the Dashboard (as applicable), its content, our Services, and our email communications to Users’ preferences. Finally, we will use the Analytics Information to understand the market in which SOLO Wellbeing operates in and for managerial reporting and business planning.

WHO WILL PROCESS YOUR DATA

We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent. These are also the categories of third parties with whom SOLO Wellbeing has disclosed personal information in the preceding 12 months. 

We will share your information with our service providers helping us to operate the Technology.

We will share your personal information with our service providers who assist us with the internal operations of the Technology such as Firebase Google servers. These companies are authorized to use your personal information in this context only as necessary to provide these Services to us and not for their own promotional purposes. We do not sell your personal information to third parties.

We will share your information with competent authorities, if you abuse your right to use the Technology, or violate any applicable law.

If you have abused your rights to use the Technology, or violated any applicable law, we may share your information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.

We will share your information if we are legally required.

If we are required to disclose your information by a judicial, governmental or regulatory authority.

We will share your information with third parties in any event of change in SOLO Wellbeing’s structure.

If the operation of the Technology is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share your information only as required to enable the structural change in the operation of the Technology.

We do not sell your personal information

We do not sell your personal information and have not done so in the preceding 12 months.

SECURITY AND DATA RETENTION

We will retain your Information for as long as we need it for business purposes, and for record-keeping matters.

We will retain your Information for the duration needed to support our ordinary business activities operating the Service and for the duration needed to provide the Service to you and for record-keeping matters. Upon request, we will return or delete your information, unless we are required to retain such information under applicable law.

We implement measures to secure your Information

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Technology will be immune from information security risks.

INTERNATIONAL DATA TRANSFERS

We will internationally transfer your Information only in accordance with applicable data protection laws. 

If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EU 

SOLO Wellbeing is the data processor

The following is the contact information of SOLO Wellbeing, the data processor:

SOLO Wellbeing, Ltd.

24 Harakefet St. Zikhron Yaacov

Email: roy@imsolo.ai 

Legal basis under EU law for processing your personal data.

The legal basis under EU law for processing your Contact Information for the purpose of responding to and handling your inquiry, is our legitimate interests in responding to your inquiry.

The legal basis under EU law for processing Usage Information is our legitimate interests in providing you with Service.

The legal basis under EU law for processing Analytics Information is our legitimate interest in maintaining, developing and enhancing the Technology.

The legal basis under EU law for processing your Analytics Information for the purpose of handling instances of abusive use of the Technology is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.

The legal basis under EU law for processing your information with authorities or where we are legally required to share it, is our legitimate interests in complying with mandatory legal requirements imposed on us.

The legal basis under EU law for processing your information in the event of a change in our corporate structure is our legitimate interests in our business continuity.

You have certain rights to access, update or delete information, obtain a copy of your information, and object or restrict certain data processing activities.

If you are in the EU, you have the following rights under the GDPR:

Right to Access your personal data that we process and receive a copy of it.

Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.

Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.

Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.

Right to Restrict the processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Privacy Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

If you wish to exercise any of your EU rights, please contact us at: roy@imsolo.ai

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you the information that you have asked for, we will explain the reason for this.

You have a right to submit a complaint to the relevant supervisory data protection authority.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

YOUR RIGHTS AS A CALIFORNIA RESIDENT UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

Disclosure of personal information we collect about you. 

You have the right to know: the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; our business or commercial purpose for collecting personal information; the categories of third parties with whom we share personal information, if any; and the specific pieces of personal information we have collected about you.

Right to deletion. 

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection against discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

Exercising your CCPA rights

If you would like to exercise any of your CCPA rights as described in this Privacy Policy, please:

• Email/ write us at: roy@imsolo.ai

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require.

MINORS

The Technology is not directed to Candidates under 13. 

The Technology is not directed to users under the age of 13. We do not knowingly collect information or data from children under the age of 13 or knowingly allow children under the age of 13 to use the App.

CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will make efforts to proactively notify you of such changes.

From time to time, we may change this Privacy Policy. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Privacy Policy will always be accessible at roy@imsolo.ai

Last Updated: 16 June, 2020