SESAME ENABLE LTD. PRIVACY POLICY

IMPORTANT: BY USING SESAME PROPRIETARY APPLICATION KNOWN AS “Open Sesame!” (THE “APPLICATION“) YOU GIVE YOUR CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND AGREE THAT ALL PERSONALLY IDENTIFIABLE INFORMATION (“PII“) THAT YOU SUBMIT OR THAT IS COLLECTED THROUGH THE APPLICATION AND THE SERVICES (AS DEFINED BELOW) MAY BE PROCESSED IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY.
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE IMMEDIATELY CEASE YOUR USE OF THE APPLICATION.
At Sesame Enable Ltd. (the “Application Management” or “we“), we recognize that privacy is important. This policy applies to all of the software, services, information, tools, features and functionality offered by the Application Management and/or its subsidiaries and/or affiliated companies in the Application (collectively, the “Services“) and covers how PII that the Company collects and receives, including in respect of any use of the Application, is treated. If you have any questions about this policy, please feel free to contact us at info@sesame-enable.com.

Providing Details
You will not be required to provide any PII when downloading the Application, but use of the Application and the Services requires you to register. Without registering, you will not be able to access or use the Application.
Upon registration, we will ask you for a Google account to associate with the registration. The Application Management may change this policy and require additional identifying information upon registration and/or downloading the Application.
We may gather additional information while corresponding with you, for example, when you file requests, send messages, report a violation of your privacy, or request technical support from the Application Management.

Personal Information You Share
The Application and the Services are based, among other things, on identifying the Application user’s location and other information associated with the Google account, such as name, phone number, email address, and more. This information may contain PII.
Content you upload into the Application may be publicly posted in combination with your PII. Hence, you must take precautions and exercise your discretion when providing information that may identify you or anybody else. You agree to use the Application’s sharing features with a reasonable level of caution.
If you access the Application through any social media application or website, or interact with any social media plug-in in the Application (such as a Facebook “Like” button) we may receive information from your respective social media account.
We process your PII only for specific and limited purposes, including the provision of the Services. We ask only for PII that is adequate, relevant and not excessive for these purposes. Some of these purposes may include to inform you of new services we will be providing, to send you requested product information and additional materials, for promotional purposes and market research, and internally to help us improve our Services and to help resolve any problems.
We will not collect or use PII for purposes other than those described in this policy and/or in any other binding legal agreement in effect between us. If we intend to use your PII for any purposes other than those described in this policy, we will ask for your consent prior to such use. You can decline to submit PII, in which case the Application Management may not be able to provide you with the Services.

Information Gathered While Using the Application
When you use the Application, the Application Management may gather information about the way you use the Application, including details about the frequency of your Application use, the duration of your Application use or running the Application, the various services in the Application that interest you, content you use or share, the IP address through which you accessed the Application, your location and more. This information is usually gathered
automatically and is stored in the Application’s servers’ ‘log’ files.
When you use the Application, we and our business partners may collect certain information about your device through technology such as cookies, web beacons, log files, or other tracking/recording tools. The information we collect through the use of tracking technologies includes, but is not limited to, IP address, browser information, referring/exit pages and URLs, click stream data and how you interact with links on the Application, the Services, domain
names, landing pages, page views, and cookie data that allows us to uniquely identify your browser, mobile device type, mobile device IDs or other persistent identifiers, and location data collected from your end device. Some or all of this data may be combined with other personally identifying information described above. We use this information to:

  • Remember information so that you will not have to re-enter it during your visit or the next time you visit the Application,
  • Provide custom, personalized content and information,
  • Monitor the effectiveness of the Application and Services and our marketing campaigns,
  • Monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns,
  • Diagnose or fix technology problems reported by the users or engineers that are associated with certain IP addresses or user ID’s, and
  • Automatically update the Application on your system and related devices.
  • Most browsers or devices may allow you to block cookies but you may not be able to use some features on the Application if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not).

Links to other sites and applications may be provided by the Application Management as a convenience to our users. The Application Management is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. This privacy statement applies solely to PII collected by us.

Use of the Information
The details you will provide and records of your actions when using the Application that will be collected, including PII, will be stored in the Application Management’s database. The use of the Application, including this privacy policy, indicates your consent to the storage and management of this data in the Application Management’s database. The information in the database will be used in accordance with the provisions of this privacy policy or the  rovisions of any law – for the goals specified below:

  • To allow you to use the Application.;
  • To identify you in repeated log-ins into the Application and to spare you the need to re-enter your details every time.
  • To improve and enrich the Application, including the creation of new services and contents that fit the users’ requirements and expectations and modify or cancel existing services and contents;
  • To enable you to adjust the Application to your preferences;
  • To send you updates, notifications and other information relating to the Application, or about the Application Management’s services and products. We may send you push notifications to send you special updates in respect of the Services. Acceptance of the Terms indicates your explicit acceptance of this. You may change your personal preferences in the Application’s settings area at any time;
  • To contact you when the Application’s management believes this is needed;
  • To hold polls and surveys from time to time;
  • To share content you provide with other Application users and enable you, the Application Management and other users to communicate;
  • For purposes of analysis, control and providing statistical information to third parties. This information will not personally identify you;
  • For the proper operation, maintenance and development of the Application in general, to provide you with the features and functionality of the Service, including to provide you with support and address requests or complaints;
  • To comply with the demands of any law, regulation or other statute as well as to assist the authorized authorities and any third party when the Application Management believes it has to do so in good faith;
  • In any event of a dispute or legal proceedings between yourself and the Application Management or between yourself and other Application users;
  • For any other purpose specified in this policy.

Delivering Information to Third Parties
The Application Management will not sell or lease PII about you to any third parties for marketing purposes. The Application Management will not transfer your details, PII about you and the information collected about your activity in the Application or your location to any third parties, other than in the following cases:

  • When you use the Application, partake in activities in connection with the Services, when this is required in order to run the Application, manage it or provide maintenance for it;
  • Should you commit actions that appear, in the sole opinion of the Application Management, to be contrary to Sesame’s policies or the law or as an attempt to commit such actions using the Application or in connection with it. In such cases, the Application Management may deliver PII about you to the enforcement, investigation authorities, other competent authorities or third parties, as shall be required to handle the act or omission you will have performed;
  • If the Application Management will be required to deliver your details or information about you to a third party according to the law or if you will believe it is required to do so according the law;
  • During a dispute, claim, demand, or legal proceedings between you and the Application Management;
  • The Application Management has a good faith belief that access, use, preservation or disclosure of such PII is reasonably necessary to detect, prevent, or otherwise address fraud, security or technical issues;
  • Whenever the Application Management has a good faith belief that delivering the information is required to prevent severe harm to your body or property or to a third party’s person or property;
  • The Application Management may forward your details and the information that was collected following your use of the Application to other companies or organizations that are related to the Application Management, such as parent companies, subsidiaries and companies under common control with Application Management. We require these parties to agree to process such PII based on our instructions and in compliance with this notice and any other appropriate confidentiality and security measures. The Application Management may share Personal Information about you with parties who are the Application Management’s partners and its service providers, provided that they only make use of this information in accordance with the provisions of this privacy policy;
  • We provide such PII to our affiliates or other trusted businesses or persons for the purpose of processing PII on our behalf in Israel and/or abroad. We require that these parties agree to process such PII based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures;
  • If we become involved in a merger, acquisition, or any form of sale of some or all of our assets. In the event of bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how PII is treated, transferred, or used. In any of the circumstances described in this paragraph, the information will be subject to the privacy policy of the purchaser or assignee.

Children
If you are a child under the age of 13, you must obtain parental consent (or consent from your legal guardian) prior to using the Application and/or our Services. The Application Management will not knowingly contact or engage with children under the age of 13 without said parental consent (or consent from your legal guardian). If you have reason to believe that a child has provided us with their PII, please contact us at the address given above.

Access to Personal Information
You may access your personal account in the Application at all times through the designated interface to edit or amend your personal details. If you believe information in your account is not accurate, complete or recent, you must take all required actions to fix it. Remember – incorrect, incomplete and inaccurate details may prevent you from registering to the Application and reduce our abilities to provide you with the Services.

Aggregate Information
The Application Management may use anonymous, statistic information gathered in connection with your use of the Application to operate the Services and provide them to users, improve them, add unto them, modify or cancel features and abilities and so on. The Application Management may also use the anonymous, statistical and aggregate information gathered, including by way of distribution, advertising, delivery, forwarding or otherwise making it available to other users, our suppliers who are related to operating the Application, and any other third party.

Information Retention
The Application Management does not store PII about you beyond the reasonable duration required to provide its services and for business purposes. The Application Management reserves the right to store, manipulate and transfer information about you at its exclusive discretion, should it be required to do so to comply with applicable law, in accordance with a judicial order or according to the Application Management’s needs as set forth in this Privacy Policy. Let it be clarified that transmission of this kind of information should not be construed as Application Management’s granting of consent, approval or assumption of liability for this information in any way whatsoever.

Data Security
We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.

  • We strive to maintain the reliability, accuracy, completeness and currency of PII that we collect and to protect the privacy and security of our users. We keep your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
  • We limit access to PII about you to employees, contractors and agents who we believe reasonably need to come into contact with that PII. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
  • We have physical, electronic, and procedural security measures and safeguards to reasonably protect PII. Our servers and our databases are protected by industry standard security technology, such as industry standard firewalls and password protection.
  • Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, we try to prevent such unfortunate occurrences.

Data Integrity, Accessing and Updating Personal Information
The Application Management processes PII only for the purposes for which it was collected and in accordance with this policy. We review our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve the Application and the Services. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this policy is interpreted as an obligation to store information, and we may, at our sole discretion, delete or avoid recording and storing any and all information.

  • Upon receipt of your written request and sufficient information to identify your PII, we will disclose to you the PII we hold about you. Upon your request, we will also correct, amend or delete any PII that is inaccurate and notify any third party who received this PII from us of the necessary changes.
  • We do not charge for complying with a correction request, however, for all other requests, we may charge a small fee to cover its costs. Requests to delete PII are subject to any applicable legal and ethical reporting or document retention obligations imposed on the Application Management.
  • We ask individual users to identify themselves and the PII which they are requesting to be disclosed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or automated, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.

Enforcement
The Application Management regularly reviews its compliance with this policy. Please feel free to direct any questions or concerns regarding this policy or our treatment of PII by contacting us as provided below. When we receive formal written complaints it is our policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between the Application Management and an individual.

Changes to the Privacy Policy
The Application Management may change the privacy policy from time to time. Continued use of the Application after a change to this policy indicates your acceptance of the revised policy. We encourage you to periodically review this policy for the latest information about our privacy practices. If you do not accept any of the amendments, you must cease further use of the Application.

Consent To Processing
By providing any PII to us pursuant to this policy, all users, including, without limitation, those in the United States, Israel and member states of the European Union, fully understand and unambiguously consent to this policy and to the collection and processing of such PII abroad. The server on which the Application and Services are hosted and/or through which the Application and Services are processed may be outside the country from which you access the Application and Services and may be outside your country of residence. Some of the uses and disclosures mentioned in this policy may involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country. By submitting your PII through the Application and Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this policy. If you do not consent to the terms of this policy, please do not use the Application and/or Services.

Questions
If you have any questions about this policy or concerns about the way we process your PII, please contact us at info@sesame-enable.com. If you wish to delete all information regarding your use of the Application and/or Services, please contact us at the same email address.

Your California Privacy Rights and Do Not Track Notices
California Civil Code Section 1798.83 permits customers of the Application Management who are California residents to request certain information regarding its disclosure of PII to third parties for their direct marketing purposes. To make such a request, please send an email to info@sesame-enable.com. Please note that we are only required to respond to one request per customer each year. You are also advised that the Application Management does not respond to “Do Not Track” signals.
Last updated: June 13th, 2017