This Privacy Statement describes how TOO.SOFTWARE Ltd. and our affiliated entities TOO, TOO software, TOO Playground, TOO Platform, collectively known as the ‘Company’, (or referred to as ‘we’, ‘our’, ‘us’) collect, use, process, and share your personally identifiable information. This Statement describes your choices regarding any applicable rights of access, deletion, and correction of your personal information. Where we refer to “information” in this Privacy Statement, it means any information that relates to an identified person.
This Privacy Statement applies to the Company and any other website (the “Site”) that links to this Statement. This Privacy Statement also applies to the information that we collect through the services we offer or our developer programs ( ‘the Playground’ ‘the developer platform’, ‘the TOO platform’, ‘the TOO playground’) and the Company services, (referred to as “Services”), communities, through marketing and customer engagement, and branded social media pages.
This Privacy Statement does not apply to the information we collect about employees or job applicants. This Privacy Statement also does not apply to information collected by third parties, like third-party websites, social media platforms or accounts, third-party service providers, or other third-party services or applications that integrate with our Services. This Privacy Statement also does not apply to any information that is not personally identifiable, like aggregated or anonymous information.
We may update this Privacy Statement from time to time and provide notice to you as described below in the section titled “Notice of Changes.”
Our Services are not directed at children under the age of 18, and we do not knowingly collect information from individuals under the age of 18. If you are under the age of 18, you may not use the Services or provide your information to us through the Site or otherwise.
If you are a citizen of Switzerland, the United Kingdom, or a country in the European Economic Area, we describe additional rights you may have in the European Privacy Rights statement. If you are a California resident, we describe additional rights you may have in the California Privacy Rights statement.
Personal information we collect
We collect or receive information in the ways we describe in this section.
Categories of Information We Collect:
* Information You Provide Us
* When You Create an Account
* Content or Information You Provide in the Services
* Content You Provide Through Our Site
* Support Channels or Communities
* Marketing Information
* Partner Program
* Payment Processing Information
* Technical, Device, and Connection Information
* Cookies and Other Tracking Technology
* Other Information Sources
Information You Provide Us: When you sign up to create an account in the Service, download content from the Site, fill out a form or survey or respond to communications, you provide us with information like your name, email address, address, company, phone number or other information. When you register for a community or a partner program, we collect account registration information like your name, email address, address, company, phone number, or other information. You may provide comments, communications, feedback, ratings, or other information when you use the Services or any of our communities or partner programs.
When You Create an Account: When you create an account, you provide us with your account registration and profile information (name, email address, company, and similar information). We automatically track certain information about your use of the Services, partner programs, or communities. We collect information about you when you login and how you interact with the Services, the features you use, clicks, log information about your use of the Services, and how you interact with other users. We describe the information we collect through the Services in more detail in Company Services statement.
Content or Information You Provide in the Services: The Services allow you to create connections or integrations between the third-party applications you use. When you use the Services, information or content is transferred from one application to another application. We collect the information that is transferred between the third-party applications. We describe the information we collect through your use of the Services in more detail in the Company Services statement. Other users may provide information about individuals when they submit content or information through the Services. For example, if a user sets up a rule that allows automated calendaring, that user will share information about the individuals they schedule meetings with via the rule. Users may also provide information about their teammates, including name and email address, to invite teammates to use the Services. Similarly, an administrator may provide your contact information if they designate you as a user, the billing contact, technical contact, or administrator. You or your administrator may integrate the Services with third-party applications. In such case, we will receive information that allows us to identify your account within the third-party applications (like name, email address, phone number, tokens, or other identifying information), the log data, content, and device information. The information or content we receive from your organization is subject to your organization’s privacy policies. When you integrate our Services with a third-party application, the information we receive depends on the settings, permissions, and privacy Statement controlled by that third-party application.
Content You Provide Through Our Site: If the Site or our social media platform pages allow you to upload content or information, we will collect the content or information you upload. For example, when you provide feedback, participate in any interactive features, surveys, contests, promotions, sweepstakes, activities, or events, you may provide us information or content.
Information You Provide Through Support Channels or Communities: You may provide information or content to us through the customer support or chat functionality we make available on the Site, in the Services, or other sites that we control. When you engage with our support team, in addition to your account information, we may ask you to provide additional information about your issue, which may include information about your technology, software, internet connection, or screenshots. To submit information to a community site, we may require you to create an account within the community (we will collect your account registration information like name, email, company, address, and phone number). If you have an account in the Services, we will associate your community membership and activities with your Services account. As a community member, you and other members may submit questions, provide answers, engage with members through chat or comments, create content or webinars to share with the community, or solicit feedback or help from other community members.
Marketing Information: We receive information about you directly from you when you engage with the Site and automatically when you engage with the Site or open or click the emails we send you (See Information You Provide Us and Cookies and Other Tracking Technology). We receive information from third-party sources like lead generation providers, content sponsors, event sponsors, or social media platforms. The information we collect from third-party sources may include marketing or demographic information, contact information (name, email, company, address, job title), information about your profile on those platforms, or information about purchasing intent. We may combine this information with the information we collect.
Partner Programs: We have several partner programs that we make available: our developer platform program (which allows third-party application providers to build integrations to the Company) and our expert program (which connects experts who help our customers set up and use the Services). Partners may also help us to market and promote our Services, generate leads, or they may resell our Services. We may add partner programs in the future. Through partner programs, we collect account registration information (like name, email address, company, and phone number), information about an individual’s technical skill set, comments, questions or feedback, rating or ranking information, images, content, or other information you provide. We may also receive information from our partners (like business contact information, address, job title, email address, or phone number). We will combine the information you provide and the information we receive with your account information.
Payment Processing Information: When you create a paid account within the Services or otherwise initiate a transaction with us, we will use a third-party payment processor to process the payment. We do not collect your credit card number, expiration date, or pin number. The transaction details we retain are those details that allow us to verify that you paid for the Services or transaction, including price, currency, date of payment, payment method, name, and account name. We will combine that information with your account information.
Technical, Device, and Connection Information: When you use the Services or interact with our Site, we automatically collect information about the device you use to access the Site or Services. When you interact with our branded social media sites, the social media platform automatically collects information and provides it to us. This information includes information that identifies you and connection type, settings, operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data.
Other Information Sources: We receive information about you from other sources like third-party service providers, public databases, and our business and channel partners. This information may include business contact information, address, job title, email address, phone number. We may combine this information with information we collect through other means.
How we use personal information we collect
We use the information we collect for the following purposes:
* to provide and support the Services,
* to improve the Services,
* to provide, support, and improve the Site, our partner programs, or communities,
* to process your requests,
* to process your payments or transactions,
* to provide you with information about our products and services,
* to combine information about you with other information we receive from third parties,
* to tailor the content or information that we provide to you,
* to protect the integrity or security of our business, the Site, Services, or third-party applications, or we may also use your information to: carry out our obligations, enforce our rights, comply with any legal obligation (including assisting our customer to comply with their legal obligations), where it is necessary for our legitimate interests, or to fulfill any other purpose for which you provided the information.
How we share personal information
We may share information when one of the following circumstances applies:
With your Consent: We may share your information with companies, organizations, and other third parties with your consent or to fulfill the purpose for which you provided the information.
With our Partners: We may share information with our partners (including resellers, referral, integration partners, experts in our community, or developer platform partners) for the purposes of the partnership agreement or to enable our partner programs.
To Provide the Services, Partner Programs, or Communities: We may share your information with your teammates, account administrators, billing, or technical account users. We will also share your information with third-party applications (at your direction or the direction of an account owner) when an account holder uses the Services. To deliver the Site, Services, partner programs, or communities, we may share your information with our service providers. If you participate in our partner programs or communities, we may share your information with other partners, community members, customers, or other users (like when you comment or share information, rate an expert, or express interest in a partner integration).
For Business Purposes: We provide information to vendors and services providers to help us provide the Site, Services, partner programs and communities, and for our business purposes. Examples of our service providers include hosting or infrastructure providers, chat widgets, helpdesk ticket providers, website hosts, customer relationship management providers, email providers, collaboration tools, and other service providers.
To Market our Services or Partner Programs: We may share information that you provide us with third-party service providers who help us market our Services or our partner programs. These service providers may provide virtual or live events, email marketing tools, sales engagement, or lead generation tools.
For Corporate Transactions: We may share personal data with actual or prospective acquirers, their representatives, and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, divestiture, or change in control involving all or a portion of our business or assets, including in connection with a bankruptcy or similar proceedings. If we undergo a sale or corporate restructure, we may disclose information to a buyer or other successor in interest.
For Legal Reasons: We may share your information if we believe that it is necessary to comply with any court order, law, legal obligation, or legal process, including to respond to any government or regulatory request. We may share your information if we believe that it is necessary to enforce our rights (including, without limitation, our rights under other legal agreements we are committed to), or the rights of our customers, or users. We may share your information if we believe that it is necessary or appropriate to protect our rights or safety or the rights or safety of our customers, other users, partners, or service providers.
With Third-Party Widgets: If you click on a widget or social media feature, like the Twitter “tweet” button or Facebook “like” button, these widgets will share information with the widget provider (like IP address, the which page you are visiting on the Services and may set a cookie to enable the feature to function correctly).
Opting Out or Correcting Your Information
Our Marketing Activities: If you would like to opt-out of receiving our marketing, you can opt-out by sending an opt-out email to firstname.lastname@example.org. If we sent you a promotional email, you may opt-out by clicking the opt-out link at the bottom of the email or sending us a return email asking to be omitted from future email distributions. This opt out does not apply to information necessary to deliver the Services, communities, or partner programs, like your account information or notices we send about the Services’ operation. If you have an account in the Services, you can manage your communication preferences (including opt-outs) in the settings page of your account profile.
Services. You can review and change your personal information in the Services by logging into the Service and visiting your account profile page. You may also send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. You can manage your communication preferences within the settings page of your account profile.
TOO.SOFTWARE takes reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in the processing and the nature of the personal data. However, no application, Internet, or email transmission is ever fully secure or error-free, and we do not guarantee the security of any personal information. You are also responsible for ensuring that your account and the passwords we provide you are protected.
Data storage and international data transfers
Information that we collect from the Site will be transferred to, and processed in the United States and in any other country where the Company or its affiliates, subsidiaries or third party service providers maintain facilities or personnel. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). We follow applicable data protection laws when transferring personal data.If you are resident in or a visitor from the EEA, United Kingdom or Switzerland, we will protect your Personal Information when it is transferred outside of such locations by processing it in a territory which the European Commission has determined provides an adequate level of protection for Personal Information; or otherwise implementing appropriate safeguards to protect your Personal Information, including through the use of Standard Contractual Clauses or another lawful transfer mechanism approved by the European Commission.
For data transfers and storage of information we collect from your use of the Services, please refer to the detail in the TOO.SOFTWARE Services statement.
You may direct any questions or complaints about this Privacy Statement to us by contacting us through the channels indicated in the Contacting Us section below. Residents of the EEA and Switzerland may file a complaint with a data protection authority. The data protection authority will require you first attempt to resolve any complaint with us; please see Contacting Us below to file a complaint with us.
California privacy rights
If you are a California resident, the California Consumer Protection Act (CCPA) provides you with additional rights regarding our use of your information. The rights outlined in this section do not apply to information exempted under the CCPA, including aggregated data, applicant information, or business to business communications about products or services. We do not resell personally identifiable information to any third-party. Therefore, we do not provide an opt-out mechanism on the Site.
With respect to the information that our customers collect or process using our Services, we collect and process personal information as a “service provider,” as defined in the CCPA. When we collect information for our own purposes, like when you visit our Site, when you interact with our marketing, or if you become our customer, we are not acting as a service provider. We make this distinction because our legal obligations with respect to your information are different when we act as a service provider.
To the extent provided under the CCPA, and subject to applicable exceptions, California residents have the following rights with respect to the information that we collect:
* The right to request the categories of personal information we have collected, the sources from which we collected the personal information, the categories of third parties with whom we share personal information, and the business or commercial purpose for collecting or selling (if applicable) personal information,
* To request a copy of the personal information that we have collected about you during the past 12 months,
* The right to opt-out of sales of personal information (if applicable),
* To request that we delete the personal information that we have collected from you, and
* To exercise the rights described above free from discrimination as prohibited by the CCPA.
Categories of personal information (CCPA)
For purposes of CCPA, we collect the following categories of personal information (while CCPA does not apply to applicant information, we encourage applicants to review the Applicant Privacy Statement for the categories of information applicable to applicants):
In the previous 12 months, we collected:
* Identifiers such as name, address, unique identifier, online identifier, email address, account name, or similar identifiers,
* Select Information in Customer Records such as name, signature, address, or telephone number,
* Commercial information such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies,
* Internet or Network Activity,
* Inferences from information that could be used to create a profile such as preferences, characteristics, and
* Audio, electronic, and visual information.
We have not collected the following categories of information in the previous 12 months: Biometric information such as hair color, eye color, fingerprints, retinal scans, or thermal, olfactory, or similar information.
Our customers may use the Services to collect or process any of the above types of information. We do not monitor our customer’s use of the Services and cannot guarantee that our customers do not use the Services to process any sensitive information.
Exercising your CCPA rights
California residents may exercise CCPA rights by logging into their account within the Services or by contacting us as indicated in the Contact section below. Your rights may only be exercised by you or by your designated agent. You may submit a CCPA request to know twice within a 12-month period. Your request must include enough information to allow us to:
* reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include: (1) verifying your account information if you have an account within the Service, or (2) requesting two forms of identification that are reliable for verification purposes unless the request includes sensitive information and, in which case, we may require three forms of verification and a signed declaration; and
* properly understand, evaluate, and respond to it.
We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. If we cannot verify your identity or authority, we will not fulfill your request. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
European privacy rights
If you are a resident of Switzerland, the United Kingdom, or a country within the European Economic Area (EEA), you may have rights under European data protection laws regarding the processing of your personal information. You have the right to access the personal information we hold about you and, in some cases, to ask that your information be corrected, erased, or transferred (subject to limitations in applicable law). You may also have the right to object to or request that we restrict the processing of your information. If we collected information based on your consent, you have the right to revoke your consent.
With respect to the information that our customers collect or process using the Services, our customer is the data controller, and we are a data processor. Our customer is the data controller for the content or information that they use the Services to process. Our customer is responsible for obtaining any necessary consent and/or ensuring that the customer has a lawful basis for processing personal information.
Where we collect information for our own purposes, like when we collect information when you visit the Site, when you interact with our social media pages, email campaigns or other marketing, when you register to use Service, or the information that we collect about your use of the Service, the Company is the “data controller.” Our lawful basis for collecting this information is to fulfill our contract with our customer, our legitimate interest in providing the Site and the Services, or to comply with our legal obligations. In some instances, our lawful basis for processing your information may be your consent.
We will retain information for as long as necessary to fulfill the services that the customer has requested, to comply with any laws or regulations, resolve disputes, or enforce our agreements. We may retain information longer for our legitimate business interest if retention is not outweighed by your personal rights and freedoms. Where we process information as a data processor on behalf of our customer, our customer determines the retention period.
If you would like to exercise any of these rights, you may contact us as indicated in the Contact section below. The rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of a third-party. We may request specific information from you to confirm your identity. In some cases, we may charge a reasonable fee for access to your information.
You may file a complaint with a data protection authority. The data protection authority will require you to first attempt to resolve any complaint with us. Please see the Contact section below to file a complaint with us.
Notice of change
The Services, the Site, and our business may change from time to time. As a result, we may make changes to this Privacy Statement. We reserve the right to update or modify this Privacy Statement at any time and from time to time. If we make changes to this Privacy Statement, we will post the changes on this page and will indicate at the top of this page and the date these terms were last revised. If we make material changes, we will notify you through the Services user interface, as a pop up on the Site, in an email notification, or through other reasonable means. Your continued use of the Site or Services after the date any such notice constitutes your acceptance of the modifications.
The following is our contact information:
Phone: (617) 448 2370
Attn: Dr. Assaf Zeira
Bnei-Atarot, Israel 60991