CNVRG Website and Portal Privacy Policy

Last Revised: September, 23, 2017

Accessible Labs Ltd., its subsidiaries and affiliates, d/b/a Accessible Labs (“Accessible Labs”, “Company” “we” or “us”) respects the privacy of the users of its Portal and visitors of the Site (“User” or “you”), and is committed to protect the personal information that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect and use when you use Our Service.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at  https://cnvrg.io/terms (“TOU”), into which this Privacy Policy is incorporated thereto by reference.

1.       Your Consent (PLEASE READ CAREFULLY!)

BY ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE SITE AND/OR PORTAL, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS AND/OR USE THE PORTAL AND/OR SITE.

2.       Which information we may collect on our Users?

We may collect two types of data and information from our Users:

a.            The first type of information is non-identifiable and anonymous information (Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering and/or using the Service. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Site, type of the User's device and its operating system and version, User's 'click-stream' on the Site, etc.

b.           The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

·             Users of the Portal and/or the Site may automatically provide their IP address (or Mac Address, as applicable), mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below. In addition, our authorized third party service providers may collect User’s advertising identifiers. We note that we may collect, use and provide access to the User's advertising identifier in accordance with the applicable platform provider's policies.  

·             In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User:

§  Details the User provides when opening an Account and signs up to the Service, such as User's name, e-mail address, company name and password;

§  When providing technical support, we may have access to Personal Information included in the User Data which are stored on your behalf by Accessible labs (User Data which you have uploaded to the Portal); and

§  Personal Information may be collected from the details the User may provide us while contacting us via the Site, the support e-mail address available on the Site, and/or via the massage box available therein. Visitors of the Site, who are interested in our Services, may also provide their work e-mail address.

§  To the extent that you wish to keep receiving our Service following the Free Trial Period, you will be required to use certain Online Payment Processors which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information) (see section 6 below regarding the payment method). We will not store such information on our servers. We only keep token information such Online Payment Processors provide us with, and such information is strictly secured.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms of Use and the Privacy Policy.

3.       How Do We Collect Information on Our Users?

There are two main methods we use:

a)     We collect information through your entry, connection, access and/or use of the Portal and/or Site. In other words, when you are using the Site and/or Portal we are aware of it and may gather, collect and store the information relating to such usage (such as the Non-personal Information detailed above and your IP address).

b)    We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and open an Account and when you contact us via the Site. We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

4.       What are the Purposes of the Collection of Information?

We collect Non-personal Information and Personal Information in order to provide the Service.

Non-personal Information is collected in order to:  

  • Use it for statistical and research purposes and for customization and improvement of our Service and our products.
  • Provide and improve the Service for our commercial purposes.

  • Improve the quality of the Service by formulating, customizing and enhancing the User's experience.

  • Personal Information is collected in order to:  

  • Provide and improve the Service.

  • Improve the quality of the Service by formulating, customizing and enhancing the User's experience.

  • Allow us to contact Users with proposals and tailored information regarding our products, events, offers, services, features, enhancements, special offers, upgrade opportunities, and events of interest etc. (including by way of newsletter).

  • Be able to contact Users for the purpose of providing them with technical assistance and support.

  • Verify the User's identity when he/she signs in to the Service, as well as verifying User's identity for the purpose of dealing with inappropriate interactions of User and/or fraudulent use of our Service.

  • Enable payment through third party Online Payment Processors. Please note that we do not collect and store credit card or other financial information.  

  • 5.       Sharing Information with Third Parties

    Accessible Labs will not share any Personal Information it collects with any third party, other than in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User's support requests; (e) to respond to claims that any content available on the Service violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of Accessible Labs, its Users, or the general public; (h) when Accessible Labs is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) to collect, hold and/or manage your Personal Information through Accessible Labs 's authorized third parties service providers (including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) to store or process your Personal Information through Accessible Labs 's affiliated companies, which may be located in a country that does not have the same data protection laws as your jurisdiction. Accessible Labs requires its affiliated entities to agree to processing your Personal Information in compliance herewith; (k) cooperate with third parties for legitimate business purposes, including without limitation, enhancing the User's experience; (l) to enable payment through certain online payment method (see section 6 below); and/or (m) pursuant to your explicit approval prior to the disclosure.

    For avoidance of doubt, Accessible labs may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Service.

    6.       Payment

    We accept certain online payment methods, using our Online Payment Processors, which enable Users to send and receive payments securely online using a credit card or bank account. We may add or change the Online Payment Processors at our sole discretion. Accessible Labs is not affiliated with such Online Payment Processors (for more information see our TOU), as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Processors is at the User's discretion and sole liability and risk. It is the User's responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

    7.       Deletion or Modification of Personal Information

    Your data is yours. If for any reason you wish to delete or modify your Personal Information you can do so via your Account. In the event that you wish to cancel your Account you may close your Account using the Account settings or you can send us an e-mail of your request to:info@cnvrg.io, and we will close your Account and delete any Personal Information therein pursuant to any applicable privacy laws. We will retain and use your Personal Information for a reasonable time after termination as necessary to comply with our legal or business requirements or obligations (including as required by applicable law), to resolve disputes, to enforce our Terms and/or to enable the User to reinstate his/her Account.

    Aggregate and/or anonymous information derived from your Account and/or use of the Service may remain on Accessible Labs' servers indefinitely.

    8.       Minors

    The Site and/or Portal are intended for Users over the age of thirteen (13). Therefore, Accessible Labs does not intend and does not knowingly collect Personal Information from minors under the age of thirteen (13) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the Service. If we learn that we collected Personal Information from minors under the age of thirteen (13) we will delete that information as quickly as possible.

    9.       Security

    We take reasonable measures to maintain the security and integrity of our Site and/or Portal and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. The Personal Information is hosted on the AWS cloud servers which provide advanced strict security standards (both physical and logical). Furthermore, we make use of proprietary firewall. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur. WE WILL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER DATA.

    10.    Third Party Service Providers

    We may be using third party software or service in order to collect, host, store and/or process the information detailed herein. Accessible Labs uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such software include without limitation, Amazon Web Services which privacy policy can be found at https://aws.amazon.com/privacy/, Google Analytics which privacy policy can be found at http://www.google.com/intl/en/policies/privacy/ However, Accessible Labs does not control such third party service providers. Please read their terms of use and privacy policies to understand their privacy practices.

    11.    International Data Transfer

    We transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

    12.    Links to Third Party Websites 

    Certain links provided herein permit our Users to leave the Portal and/or the Site and enter non-Accessible Labs sites or services. These linked sites and services are not under our control. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

    13.    Cookies and Other Tracking Technologies

    When you access or use the Site and/or Portal, Accessible Labs and/or our third party service providers may use industry-wide technologies such as “cookies” or other similar technologies, which store certain local information on your device or on the Site (“Cookies”), which may enable, inter alia, automatic activation of certain features and make the User’s experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored on your computer or on your device. Accessible Labs and/or our authorized third party service providers may access such information. Accessible Labs and/or our authorized third party service providers may use both session cookies (which expire once you close the web-browser) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Cookies included in the Service may store non-personal information (such as the different pages viewed by a User within the Site). It is easy to prohibit and/or delete the Cookies, inter alia, through the Settings option of your device or web-browser. Most platforms will allow you to erase cookies from your computer's hard drive or from you device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Cookies you may use the settings option of your device or according to the specific instructions provided by the third party service provider's privacy policy and terms of use. However, if you block or erase cookies, or change the settings of your device, your online experience may be limited. Third-party Cookies usually store only a Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc. Accessible Labs does not control such third party service providers.

    14.  Direct Marketing

    You hereby agree that we may use your contact details you provided us with (including, without limitation, e-mail address and phone number) for the purpose of providing you commercial and/or non-commercial materials related to Accessible Labs' current and/or future products, services and other updates and new features which may be of interest to you. You may withdraw your consent by sending a written notice to Accessible Labs' e-mail address appears in the Site or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.

    15.    Changes to the Privacy Policy

    The terms of this Privacy Policy will govern the use of the Site and/or Portal and any information collected with respect thereto. Accessible Labs reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the homepage of the Site and/or the Portal or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site and/or Portal after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

    16.    Got any Questions?

    If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: info@cnvrg.io and we will make an effort to reply within a reasonable timeframe.