Legal
Privacy Notice for California Residents
Last updated: May 20, 2024
This Privacy Notice for California Residents supplements the information contained in the Privacy Policy of PointFive Ltd. ("PointFive" or "we") and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you") in connection with the use of our Services (as defined in PointFive's Terms of Use).
We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act ("CPRA") and other California privacy laws in effect or as may take effect from time to time. Any terms defined in the CCPA or the CPRA have the same meaning when used in this notice.
1. Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers | NO |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information | NO |
| C. Protected classification characteristics under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information | NO |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | NO |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information | NO |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement | NO |
| G. Geolocation data | Physical location or movements | NO |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act) | Education records directly related to a student maintained by an educational institution or party acting on its behalf | NO |
| K. Inferences drawn from other personal information | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | NO |
| L. Sensitive personal information | Social Security, driver's license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; biometric information; health data; sex life or sexual orientation data | NO |
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us.
- Directly from you. For example, through information we ask from you when you subscribe and engage our Services.
- Directly and indirectly from you when using our Services. For example, usage details collected automatically in the course of your interaction with our platform.
2. Use of Personal Information
We may use or disclose the personal information we collect, sell or share, for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided
- To provide you with email alerts and other notices concerning our Services
- To improve our Services to you
- To provide, support, personalize, and develop our products and services
- To create, maintain, customize, and secure your account with us
- To help maintain the safety, security, and integrity of our products and services, databases and other technology assets, and business
- To provide you with support and to respond to your inquiries
- For testing, research, analysis and product development
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Subsidiaries and affiliates
- Our clients or their agents for which you have engaged in a business contract
- Service providers and contractors
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with our Services
- Data aggregators
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Identifiers
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Commercial information
- Internet or other similar network activity
In the preceding twelve (12) months, we have not sold any personal information. While we do not sell personal information in exchange for any monetary or other valuable consideration, we do share personal information for other benefits that could be deemed a "sale," as defined by the CCPA. This includes sharing personal information with advertising networks, website analytics companies, and event sponsors.
4. Your Rights and Choices
The CCPA and CPRA provide consumers (California residents) with specific rights regarding their personal information.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about you
- Our business or commercial purpose for collecting that personal information
- The categories of third parties with whom we share that personal information
- The specific pieces of personal information we collected about you (also called a data portability request)
Correction of Inaccurate Personal Information Rights
You have the right to request that we correct inaccurate personal information about you. Once we receive and confirm your verifiable consumer request, we will use commercially reasonable efforts to correct your personal information as directed by you.
Deletion Request Rights
You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information or otherwise perform our contract with you
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity
- Debug products to identify and repair errors that impair existing intended functionality
- Exercise free speech or exercise another right provided for by law
- Comply with the California Electronic Communications Privacy Act
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest
- Enable solely internal uses that are reasonably aligned with consumer expectations
- Comply with a legal obligation
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it
5. Exercising Your Rights
To exercise the access, data portability, correction and deletion rights described above, please submit a verifiable consumer request to us by either:
- Sending an e-mail to us at [email protected]
- Sending a letter to us at 114 Yigal Alon St., 6744320 Tel Aviv, Israel
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
6. Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
7. Personal Information Sales Opt-Out and Opt-In Rights
You have the right to direct us to not sell or share your personal information at any time (the "right to opt-out"). We do not sell or share the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at [email protected]. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
8. Limitation of Use and Disclosure of Sensitive Personal Information
You have the right to direct us to limit our use of your sensitive personal information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services. To exercise this right, you (or your authorized representative) may submit a request to us at [email protected]
9. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, we will not:
- Deny you use of our Services
- Charge you different prices or rates for goods or services
- Provide you a different level or quality of goods or services
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
10. "Do Not Track" Disclosures
We adhere to the standards set out in this Privacy Notice and do not monitor or respond to Do Not Track browser requests.
11. Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. You are responsible for periodically visiting our website and this Privacy Notice to check for any changes. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.
12. Contact Information
If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us: