Last Updated 15/10/2018This document sets forth the Privacy Policy of Depoint Management Solutions Ltd., registered in Israel with company registration number 515628204, and having its registered office address at HaTayelet 20, Ashdod, Israel (“We”, “Us”, “Depoint”).We provide workplace management solutions to our customers via our platform, accessible from mobile and fixed devices (the “Customer”, “Platform” respectively).Depoint is committed to protecting your privacy. For the purposes of this Privacy Policy, Personal Data shall mean any information provided to Depoint that relates to an identified or identifiable individual (“Personal Data”).This Privacy and Cookie Policy (“Policy”) details how We collect, store and process Personal Data that we receive via the services provided through our Platform (the “Platform”) and other Personal Data collected from users who visit our website at www.depoint.co (the “Website”); from our Customers, organizations that use the Services; and from Customer’s personnel, including employees and other users who use the Services; (collectively “you”, “User”).This Policy governs the use of the Website and the Platforms (collectively – the “Services”) by our users, including, without limitation:

• When you access the Services, whether by using your computer, your mobile device or any other device.
• Email, other electronic messages including SMS, telephone, web chat, website/portal and other communications between you and Us

In this context, Depoint is the data processor and the Customer is the data controller, as these terms are defined under the General Data Protection Regulation (as defined below).Please note: you are not obligated by law to provide us with any Personal Data. However, without providing it you will not be able to use the Platform, which require registration and provision of details. You hereby acknowledge and agree to the collection of your Personal Data by the Platform and/or Website, at your own free will and for the purposes described in this Policy, and that We may retain such Personal Data in accordance with this Policy and any applicable laws and regulations.We collect and process Customer Personal Data in accordance with a Customer’s instructions, we only use that Personal Data to provide services consistent with those Customer instructions.The collection, use and retention of Customer Personal Data (including Customer’s employee data) is, at all times, controlled by the Customer (as the employer), and any questions or requests with regard to a Customer’s Personal Data should be directed to that Customer.Please read the following Policy carefully to understand our policies and practices regarding the processing of your Personal Data.

Table of Contents

1. Personal Data Collected
2. Legal Basis for Processing
3. How we use your Personal Data
4. Disclosure of your Personal Data
5. Security
6. Where we store your Personal Data
7. How long we keep your Personal Data
8. Your Rights
9. Third Party Websites
10. How to complain
11. Children
12. Changes to our Policy
13. IP Addresses and cookies
14. Contact

1. Personal Data Collected

We may collect, process and/or store your Personal Data from a number of sources, primarily to provide services under our contracts with the Customers and to improve those products and services. Personal Data we collect may include the following:information that you provide:

• when filling in forms on our Website, such information may include your name, phone number, and e-mail address;
• when using the Platform – This includes information provided by you at the time of subscribing and using the Platform, posting material or requesting further information or services. Such information may include your full name, ID number, employee ID number, mobile phone number, role or position within the Customer’s organization, details of all actions that you carry out through the Platform and of the provision of services to you

information that the Customer (including other Customer’s users and employees) provides about you when filling in forms at the time of registration to our Platform and using it. This may include your full name, ID number, employee ID number, mobile phone number, role or position within the Customer’s organization, and other information related to your tasks and roles within the Customer’s organization, including your practices, trainings, attendance and sick leaves details, employment contracts, compensation, uniform size, equipment details, promotions, bank account information, employment hearing letters, among other details that are collected in the course of the Customer’s operation.photographs and video recordings that you may appear in, that were uploaded to the Platform in the course of the Customer’s intended use of the Platform as workplace management solutions (e.g. for describing problems or damages, sharing photos of events, training material, promotions, newsletters, etc.) whether provided by you or by the Customer. We require our Customer and its users (employees) to use the feature of uploading photos and videos only if required for the purpose of Customer’s management. By using the Platform you consent to our collection of such materials via the Platform, as part of provision of our services to the Customer.information we request when you report a problem to us relating to the Platform or the Website. Please note that if you contact Us, We may keep a record of that correspondence.information collected via automated means – details of your use of the Platform and visits to the Website including traffic data, location data, weblogs and other communication data, and the resources that you access from. We may collect such information via automated means, for example by using cookies when you visit Platform – for further details on cookies and collection of data by automated means please see Sections 2 and 12 below.Data minimization – we request our Customers to use the Platform only for the intended purpose of management solutions, and to avoid uploading excessive Personal Data to the Platform. However, we cannot assure and we are not responsible whatsoever for Customer’s practices and policies with respect to privacy and data protection.Sensitive Personal Data -We do not intentionally collect sensitive Personal Data (for example, information revealing race, ethnic origin, political opinions, religion, etc.) and we ask you not to upload such information to the Platform or Website

2. Legal Basis for processing

We will process your Personal Data only when we have one of the following ground:

• your consent;
• our legitimate interests in performing our contract with our Customer, and performing our obligations under that contract.
• Where we have a legitimate interest, e.g. managing our business, or defending ourselves from claims, subject to such processing not overriding your own rights and freedoms;
• Exceptionally, when necessary in the public interest, for example when law enforcement agencies request information to investigate a crime.

3. How we use your Personal Data

We use the information collected about you in the following ways:

• To provide you access to the Platform and use of the Services.
• To provide the Customer, and Customer’s users (i.e. employees) access to the Platform and use of the Services.
• To carry out our obligations arising from any contracts entered into between our Customer (on whose behalf you are using the Services) and Us.
• To carry out our obligations arising from any contracts entered into between our Customer (on whose behalf you are using the Services) and Us.
• For compliance with a legal obligation (e.g., to respond to a court order or a regulator).
• To protect our rights, privacy, safety, networks, systems and property, or those of other persons
• In order to exercise our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to us or third parties with whom we work.

4. Disclosure of your Personal Data

We may disclose your Personal Data to third parties only in the following cases:

• When we use a cloud computing partner for the storage of data;
• when we use third party services that are required for the performance of our business, for example – to send mobile notifications, when we use third party site for analytics purposes;
• in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
• if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or in order to enforce or apply our Platform Terms and Conditions and other agreements, but we will extend reasonable efforts to limit such disclosure to what is necessary and when possible, provide you with notice of such disclosure; and/or
• to protect the rights, property, or safety of Depoint, the Platform, the Website, our users and any third party we interact with to provide the Platform.

5. Security

We take appropriate measures to ensure that all Personal Data is kept secure including security measures to prevent Personal Data from being accidentally lost, or used or accessed in an unauthorized way, for the duration of your use of our Services. We limit access to your Personal Data to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to the Platform or the Website, therefore any transmission remains at your own risk. Once we have received your information, we will use strict procedures and security features in order to prevent unauthorized access.

6. Where we store your Personal Data

The data that We collect from you and process as a result of your use of the Services may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. We have measures in place to ensure that when your Personal Data is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. By submitting your Personal Data, you agree to this transfer, storing or processing. Please note that the USA does not have the same data protection laws as the EEA.If you would like further information please contact Us (see ‘Contact’ below).

7. How long we keep your Personal Data

We will hold Personal Data for so long as we have an obligation to the Customer to provide the Services or to retain the Personal Data, and thereafter until such time as we delete the Customer’s account in accordance with our engagement with our Customer.

8. Your rights

Under the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (EU) (“GDPR”) you have a number of important rights. These rights include:

• right to be informed;
• right to access the personal data;
• right to correct the personal data;
• right to ask for deletion of the personal data;
• right to ask to restrict the processing of the personal data;
• right to object to the processing of the personal data;
• right to object to automated decision-making and profiling;
• right to data portability;
• right to withdraw the consent, if processing is based on consent.

If you would like to exercise any of those rights, please:

• contact us using our Contact details below,
• let Us have enough information to identify you,
• let Us know the information to which your request relates.

9. Third Party Websites

The Platform and/or the Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any Personal Data to these websites.

10. How to complain

We hope that We can resolve any query or concern you raise about our use of your information.The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, reside, or where any alleged infringement of data protection laws occurred.

11. Children

We do not knowingly collect Personal Data from children under the age of 13. If you are under thirteen, please do not submit any children’s Personal Data to Depoint. If you have reason to believe that a child under the age of 13 has provided Personal Data to Depoint, please contact us, and we will endeavor to delete that information from our databases.

12. Changes to our Policy

We reserve the right to modify this Privacy and Cookie Policy at any time. Any material changes we may make to our Policy in the future will be notified and made available to you using the Website.

13. IP Addresses and cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, customer support and to collect aggregate information for internal reporting purposes.In addition, our Website and Platform use cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users, which helps us to provide you with a good experience when you browse our Platform and/or Website and also allows us to improve the Services.The cookies we use are “analytical” cookies. Some of the common uses for our cookies are as follows:

• to recognize and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our Platform works, for example by ensuring that users are finding what they are looking for easily.
• to identify and authenticate a user across different pages of our Platform, within our own Platform, in a session or across different sessions. This is so that the user does not need to provide a password on every page the user visits; and
• to be able to retrieve a user’s previously stored data, for example, information that the user previously submitted to the Platform, so as to facilitate reuse of this information by the user.

14. Contact

All questions, comments and requests regarding this Policy should be addressed to: HaTayelet 20 Ashdod, Israel, 744200 Email: [email protected] Phone: +972 52-630-3332