Multyx Privacy Policy

EFFECTIVE AS OF November 1,  2023

1.        PURPOSE AND SCOPE
   1.    At Multyx, we respect your privacy and data protection rights and recognize the importance of protecting the personal data we collect and process. This Privacy Policy is designed to help you to understand which personal data we collect about you and how we use and share it.
   2.    When we refer to Multyx, we mean Multyx Software Ltd., a company registered in Israel, 23 Kol Israel Haverim St. Haifa 3543214 (“Multyx“, “we“, “us“, “our“).
   3.    This Privacy Policy applies to you if you:

• interact with any of our websites (including www.Multyx.ai) or our social media pages (collectively, the “Sites”) (“website users“);
• use our products and services (collectively, the “Multyx Services“);
• receive marketing communications from us.
  4.    For the purposes of the General Data Protection Regulation (or any successor or equivalent legislation in the UK) (“GDPR“) Multyx shall be considered a “Controller” regarding Website information for Website Users, and a “Processor” for any personal data received as part of the Multyx Services.

2.        PERSONAL DATA COLLECTED BY US
   1.    PERSONAL DATA WE COLLECT AND RECEIVE

The personal data that we collect or receive about you broadly falls into the categories set out in the following table. Some of this information is information you, as the data subject, provide voluntarily when you interact with us. Other information may be received, accidentally, tangentially or inadvertently as part of the provisions of the Multyx Services to our customers.

1.  We may collect the following personal data about:
   1.               Our website users;
   2.               Recipients of marketing communications; and
   3.               Marketing prospects.

Such personal data may include registration, contact, and company information:

• first and last names;
• email addresses;
• phone numbers;
• company/employer name;
• your role or position in the company.

We may collect device data for visitors to our Websites:

• operating system type and version number, manufacturer and model;
• browser type;
• screen resolution;
• IP address;
• unique device identifiers.
• the website you visited before browsing to us;
• how long you spent on a page or screen;
• how you interact with our emails;
• navigation paths between pages or screens;
• date and time;
• pages viewed;
• links clicked.
  2.  We may collect the following personal data about:

Our customer’s personnel interacting with us

Information saved, collected and otherwise processed by our customer’s end users and clients which are incidentally or inadvertently made available to us as part of our support and maintenance services.

We do not need or retain such information for any purpose other than for archival purposes or for support services to our customers. Such personal data is provided and used by us based on a Data Privacy Addendum signed by us (as Processors) and our customers (as Controller)

2.    Cookies and Tracking Technologies

Some device data, service data and third party source data is collected through the use of first or third party cookies and similar technologies. For more information about cookies we use and how to configure your browser to prevent use of cookies and remove cookies, please see our Cookie Policy.

3.        HOW WE USE YOUR PERSONAL DATA
   1.    We collect and process your personal data only for the following purposes and on the following legal basis:

• Providing and operating our Services and Sites: We process your personal data to perform our contract with you for use of our Services and Sites and to fulfill our obligations under applicable terms of service and laws. Where we have not entered into a contract with you, we process your personal data in reliance on our legitimate interests to operate the Services, among others based on the DPA signed with the personal data’s Controller. 
• Communicating with you about our Services and providing support: We may send you service, technical and other administrative messages in reliance on our legitimate interests in providing the Services. We also process your personal data to respond to your comments and questions and to provide support. We may be privy to or have access to some personal data of which you are a Controller – we do not use, retain or process such personal data for any purpose other than to provide You with support, and if required by You or by Law, for archival purposes only. 
• Improving the Multyx Services and Sites as provided to you: We process your personal data to improve and optimize the Multyx Services as provide to You, and we use personal data of our Website’s visitors to understand how visitors reach, access and use our Website, including to monitor usage or traffic patterns and to analyze trends.
• Maintaining security of the Services and Sites: We process your personal data to control unauthorized use or abuse of the Multyx Services and Sites, or otherwise detect, investigate or prevent activities that may violate Multyx policies or applicable laws, in reliance on our legitimate interests to maintain and promote the safety and security of the Multyx Sites and Services.
• Carrying out other legitimate business purposes: including support services, invoicing  and fraud detection and prevention.
• Complying with legal obligations: We process your personal data when cooperating or complying with public and government authorities, courts or regulators in accordance with our obligations under applicable laws and to protect against imminent harm to our rights, property or safety, or that of our users or the public, as required or permitted by law.
  2.    In certain circumstances, we may collect your personal data on a different legal basis. If we do, or if we use your personal data for purposes that are not compatible with, or are materially different than, the purposes described above We will explain how and why we use your personal data in a separate notice  and obtain your approval beforehand.

4.        SHARING YOUR PERSONAL DATA
   1.    We may disclose some or all of the personal data we collect to the following third parties:

• Any third party we require in order to provide the Services as further detailed in the DPA 
• Our other Service Providers: consultants, vendors  we require for the operation of our business and provisions of our Services;
• Professional Advisors: such as lawyers, auditors and insurers, in the course of the professional services that they render to us.
• Compliance with Law Enforcement: to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• With any third party we require in order to enforce the terms and conditions that govern the Services; and in order to prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
• Merger and Acquisition: Parties to transactions or potential transactions (and their professional advisors) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business, assets, or equity interests of Multyx.

2.    We may also share aggregated or anonymized information with third parties for other purposes. Such information does not identify you individually, but may include usage and technical information. If we are required under applicable law to treat such information as personal data, then we will only disclose it as described above. Otherwise, we may disclose such information for any reason.

5.        RETENTION OF YOUR PERSONAL DATA

We retain your personal data only for as long as necessary to fulfill the purposes set out in this Privacy Policy.

6.        TRANSFERS OF YOUR PERSONAL DATA
   1.    The Services and Sites are provided and hosted in in the United States or in the EEU territory. We may be required to transfer, and process, your personal data outside of the country or region in which you are a resident. We will protect your personal data in accordance with this Privacy Policy wherever it is processed.
   2.    Our service providers who process your personal data on our behalf may also transfer personal data outside the country in which you are resident. Where such transfers occur, we will make sure that an appropriate transfer agreement is put in place to protect your personal data.
   3.    If you are a resident of the EEA, the UK or Switzerland, for such personal data for which we are Controllers we will protect your personal data when it is transferred outside of the EEA, the UK or Switzerland by processing it in a territory which the European Commission has determined provides an adequate level of protection for personal data; or otherwise ensuring appropriate safeguards are in place to protect your personal data including by applying the applicable Standard Contractual Clauses within a DPA. For such personal data for which we are a Processor, we shall protect and follow the requirements and adhere to the provisions of the applicable DPA signed by and between us and you as the Controller.
7.        HOW WE STORE AND SAFEGUARD PERSONAL DATA

We put in place appropriate measures that are designed to secure your personal data. Such measures are within the highest acceptable and generally used data protection measures available in our industry.

8.        YOUR PRIVACY RIGHTS AND CHOICES
   1.    Depending on your location and subject to applicable laws, you may have certain data protection rights. If you are a resident of the EEA or the UK you have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details at the bottom of this policy.
• You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.
• You have the right to opt-out of marketing communications we send you at any time. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by clicking on the “unsubscribe” or “opt-out” link in the communications we send you. Please note, however, that it may not be possible to opt-out of certain service-related communications. You can let us know at any time if you do not wish to receive marketing messages by contacting us using the contact details at the bottom of this policy.
• Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  2.    If you are a California resident, you can find information about how we use your personal data and about your privacy rights in the relevant section of this notice below.

9.        CHILDREN’S PRIVACY

Our Services and Sites are not intended for use by anyone under the age of 18. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, you may not attempt to register for our Services or send any information about yourself to us, including your name, address, telephone number, or email address. If we become aware that we have collected personal data from someone under the age of 18 without verification of parental consent, we will delete that information promptly.

10.    CHANGES TO THIS NOTICE AND QUESTIONS
    1.                       We may amend this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update it, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If we make material updates to this Privacy Policy we will update the effective date at the top of the Privacy Policy.
    2.                       If you have any questions, comments or concerns about this Privacy Policy or the way your personal data is being used or processed by Multyx, please submit any questions, comments or concerns using the Contact Us link in the footer of this page.

For any question or clarifications please contact us at info@multyx.ai  

1.        COLLECTION AND USE OF PERSONAL DATA OF CALIFORNIA RESIDENTS
   1.    SCOPE

Except as otherwise provided, this part of the Privacy Policy applies only if you are a California resident. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA“), the California Privacy Rights Act of 2020 (“CPRA“), and any regulations promulgated under either law, in each case, as amended from time to time.

This Section does not apply to;

• information exempted from the scope of the CCPA;
• activities governed by a different privacy notice, such as notices we give to California personnel or job candidates; or
• Personal Information we collect, use, and share on behalf of our customers as a “service provider” under the CCPA.

2.    YOUR CALIFORNIA PRIVACY RIGHTS

You have the following rights:

• Right to Information/Know You can request whether we have collected your Personal Information, and in certain cases, the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information we have collected.
  • The categories of sources from which we collected the Personal Information.
  • The business or commercial purpose for collecting, sharing, and/or selling Personal Information.
  • The categories of Personal Information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom Personal Information was sold, shared, or disclosed for a business purpose.
• Right to Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Right to Correction. You can request that we correct inaccurate Personal Information that we have collected about you.
• Right to Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Right to Opt-Out of Tracking for Targeted Advertising Purposes. While we do not sell Personal Information for money, like many companies, we use services that help deliver targeted ads (also known as interest-based ads) to you, as we have described in the “How and Why We Use Your Personal Data” section above. The CCPA classifies our use of some of these services as “sharing” your Personal Information with the advertising partners that provide the services, from which you have the right to opt-out.
• Right to Nondiscrimination. You are entitled to exercise the rights described above free from discrimination prohibited by the CCPA.

3.    HOW TO EXERCISE YOUR RIGHTS

• Right to Information/Know, Access, Correction, and Deletion. You can exercise any of these rights by submitting a request through our dedicated email here: info@multyx.ai or by mailing us at 23 Kol Israel Haverim St. Haifa 3543214, Attention: Privacy.
• Right to Opt-Out of Tracking for Targeted Advertising Purposes. You can submit requests to opt-out of tracking for targeted advertising purposes by referring to our Cookie Policy. Your request to opt-out will apply only to the browser and the device from which you submit the request.

Verification of Identity. We will need to verify your identity to process your information/know, access, correction, and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require you to provide government identification, give a declaration as to your identity under penalty of perjury, and/or provide additional information. These rights are not absolute, and in some instances, we may decline your request as permitted by law.

Authorized Agents. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of the valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.

4.    PERSONAL INFORMATION THAT WE COLLECT, USE AND DISCLOSE

The table below describes our Personal Information practices by reference to the categories in the “Personal Data Collected by Multyx” section above and the categories described in the CCPA (Cal. Civ. Code Section 1798.140(v)) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. Note that:

• We do not “sell” personal information as defined by the CCPA and have not sold Personal Information in the preceding 12 months.
• We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.