You are not legally required to provide us with any Personal Data (defined below), and may do so (or avoid doing so) at your own free will.
If you do not wish to provide us with such Personal Data, or to have it processed by us or any of our Service Providers (defined below), please simply do not enter our Sites or use our Service. You may also choose not to provide us with “optional” Personal Data, but please keep in mind that without it we may not be able to provide you with the full range of our services or with the best user experience when using our Service.
1. Data Collection
We collect various types of personal data regarding our Users as well as data regarding Visitors to our Sites. Such data is typically collected and generated through your interaction with us or our Service, through automatic means, or directly from you, from other Users, from our customers, or from other third parties (including Service Providers and “Cookies”, as hereinafter defined).
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “Personal Data“):
Data automatically collected or generated: When you visit, interact with, or use our Service, we may collect, record or generate certain technical data about you. We do so either independently or with the help of third party Service Providers (as defined in Section 4 below), including through the use of “cookies” and other tracking technologies (as detailed in Section 5 below).
Such data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device data (like type, operating system, mobile device id, browser version, locale and language settings used), date and time stamps of usage, the cookies and pixels installed or utilized on such device and the recorded activity (sessions, clicks and other interactions) of Visitors and Users in connection with our Service. In addition, phone calls (e.g. with our customer success or product consultants) may be automatically recorded, tracked and analyzed, for purposes including analytics, service-, operations-, and business quality control and improvements, and record-keeping purposes.
User Data received from you: When you contact us or sign up to the Service or request a demo or purchase a subscription to our Solution, you may provide us with Personal Data. This includes your name, address, billing information, account login details (e-mail address which are immediately hashed and passwords), images you may provide, related websites as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service.
Once you are logged in to our Service, you may submit various additional details and documentation concerning yourself. This could include your employee ID, job title and other information you or your organization choose to submit in order to further and more fully utilize the various features of the Service (collectively, “User Data”). If you register as a participant in any of our events, you may provide us with additional details such as your participation eligibility and preferences, your experience relating to ReturnGo and its Solutions, your meal or accommodation preferences, and any other relevant information.
User Data received from our customers and Users: Our customers and Users may provide us with the contact details of their employees, team members and colleagues, in order for us to contact, invite or subscribe them as Users to our Service. Such data typically includes these individuals’ names, phone numbers and work e-mails.
Data received from other third parties: We may receive Personal Data concerning you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your Personal Data from its organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and work position) from our business partners or service providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn and other data sources.
We receive Personal Information concerning you from our customers and third party platform we integrate with such as Shopify™. Such data includes details about you purchase and order, purchase history, IP address and identifiers, information detailed above as such that you may provide us yourself and address.
Note that we do not receive or store your passwords for any third-party services (but may typically require your API key in order to integrate with them).
Data obtained through Analytics Tools: We use analytics tools (e.g. Google Analytics and Hotjar) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and Visitors visit or use the Sites or Service, which pages they visit and when, and which website, ad or e-mail message brought them there.
2. Data Uses
We use Personal Data as necessary for the performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Service, e.g. in understanding how our Service are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently in marketing, advertising and selling our Service to you and others and to develop our services and algorithms; providing customer service and technical support; and protecting and securing our Users, customers, Visitors, ourselves, the public and our Service.
Specifically, we use Personal Data for the following purposes:
a) To facilitate, operate, and provide our Service;
b) To verify and carry out financial transactions in relation to payments customers make in connection with the Service;
c) To authenticate the identity of our Users, and to allow them access to our Service;
d) To provide our Visitors, Users and customers with assistance and support;
e) To gain a better understanding on how Visitors and Users evaluate, use and interact with our Service, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Service;
f) To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Service, and thereby to increase your engagement and overall satisfaction with our Service. This includes contextual, behavioral and interests-based advertising based on the Visitor’s or User’s activity, preferences or other data available to us or to our business partners;
g) To contact our Visitors, Users and customers (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section 6 below);
h) To facilitate, sponsor and offer certain events, contests and promotions;
i) To publish your feedback, user story and submissions in our public forums and blogs;
j) To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
k) To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose;
l) To comply with applicable laws and regulations.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
3. Data Location & Retention
Data Location: Your Personal Data is maintained, processed and stored by us and our authorized Service Providers (defined below) in the AWS servers in US. We may also retain your Personal Data in other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required by law.
ReturnGo is headquartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
Data Retention: We will retain your Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Service and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable law and for not more than 7 years from termination of our applicable customer’s engagement with us.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us by e-mail at: [email protected]
4. Data Sharing
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b)disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and services.
Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution, marketing and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and enrichment services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, compliance and financial advisors (collectively, “Service Providers“).
These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such limited purposes as determined in our agreements with them.
Our Service Providers shall be deemed as ‘Data Processors’ in circumstances where ReturnGo assumes the role of ‘Data Controller’; and where ReturnGo acts as the Data Processor for our customer, the Service Provider shall be deemed our ‘Sub-Processor’ (as further described in Section 9 below).
Sharing Personal Data with our customers, their Users and service providers: We may share your Personal Data with the customer owning the account to which you are linked as a User (including data and communications concerning your purchases). In such cases, sharing such data means that the Customer may access it on behalf of the customer, and will be able to monitor, process and analyze your Personal Data.
Please note that ReturnGo is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the customer, that itself acts as the “Data Controller” of such data (as further described in Section 9 below).
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of ReturnGo, any of our Users or customers, or any members of the general public.
For the avoidance of doubt, ReturnGo may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
5. Cookies and Tracking Technologies
Our Sites and Service (including some of our Service Providers) utilize “cookies”, anonymous identifiers, container tags and other technologies in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by a User.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, 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.
A list of the cookies and pixels used in our Services can be found on the Cookie section in your browser when you are using our Services.
Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, service changes, log-in attempts or password reset notices, etc. Our customers, and other Users on the same account, may also send you notifications, messages and other updates regarding their or your use of the Service. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms. We may decide to send promotional email to only certain Users on our mailing list, based on their known chrematistics.
If you do not wish to receive such promotional communications, you may notify ReturnGo at any time by sending an e-mail to [email protected] , changing your communications preferences in your settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
7. Data Security
In order to protect your Personal Data held with us, we are using industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
8. Data Subject Rights
If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA) (to the extant they applicable), such as the right to request access to, and rectification or erasure of your Personal Data held with ReturnGo, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: [email protected] . We will make efforts to response as soon as possible and start the selection process within 72 hours from authorization of deletion by customer (if applicable) and identity validation of the user. Certain information may take up to 30 days to be deleted from our backup files. Certain information will not be anonymized and not deleted, if such deletion is not reasonably possible in light of the system’s architecture.
Please note that once you contact us by e-mail, we may instruct you on how to fulfill your request independently through your settings or may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
If you would like to make any requests or queries regarding Personal Data we process on our customer’s behalf, please contact the customers directly (as they are the “Data Controller” of such data – see Section 9).
9. Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes the data on behalf of the Data Controller (or business). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.
Any other Personal Data submitted to our service will only be processed by ReturnGo on behalf of our customer, which is the owner of the respective account, along with all other User Data processed on such customer’s behalf.
In such instances, our customer shall be deemed the “Data Controller” of such data, and ReturnGo will process such data on the customer’s behalf, as its “Data Processor”, in accordance with its reasonable instructions, subject to applicable agreements with such customer. ReturnGo’s Service Providers shall act as designated Sub-Processors in these instances. ReturnGo’s customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
10. Job applications
We may collect information provided to us by job candidates (“Applicants”) when they apply to a position in our super great company. ReturnGo welcomes all qualified Applicants to apply to any of the open positions by sending us their contact details and CV (“Applicants Information”). Applicants Information will be maintained, processed and stored in Israel, US and in the applied position’s location(s), and as necessary, in secured cloud storage provided by our Third-Party Services. We are committed to keep Applicants Information private and use it solely for our internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, background checks on Applicants and contacting Applicants by phone or in writing). Please note that ReturnGo may retain Applicants Information submitted to it even after the applied position has been filled or closed so we can re-consider Applicants for other positions and opportunities and in case the Applicant is hired, for additional employment and business purposes related to their work. If you previously submitted your Applicants Information to ReturnGo, and now wish to access it, update it or have it deleted, please contact us at: [email protected] . We will be happy to assist in any manner.
11. Additional Notices
Our Service is not designed to attract children under the age of 16: We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Service, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at: [email protected] .
Arie Shenkar 1 Herzilia, Israel
Effective Date: 09/14/2020