Last updated: April 18, 2023
Eloops Ltd. (“Eloops“, “we“, “our” or “us“) develops and provides employee engagement platform (the “Platform“) that will help align employees throughout your company and create a gamified workplace experience.
Our Platform, our website available at www.eloops.com (the “Site“) and the Eloops mobile application (the “App“) allow employees, to engage and communicate with each other internally within their respective organization or company (the “Customer“).
- User Data relating to data generated by or on individuals through their engagement with our Services, during their employment with our Customer (“User” or “Users”).
- Prospect Data relating to visitors of our Site, participants at our events, prospects, partners, investors, and any prospective partner or investor, Customer or other individual (collectively, “Prospects”) who visits or otherwise interacts with any of our websites, mobile applications, online ads, and content, emails or other communications under our control (together with our Platform, Site and App – the “Services””).
You can Contact Us with any question or concern you may have regarding the service.
- Data Collection
- Data Uses
- Data Location and Retention
- Data Sharing
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Children’s Privacy
- Data Controller/Processor
- Additional Notices
1. Data Collection
We collect Personal Data regarding our Users and Prospects. Such data is typically collected and generated through the Prospect’s or User’s interaction with our Services, through automatic means, directly such Prospect or User, from our Customers, or other third parties.
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed data, will be deemed as “Personal Data“):
- Data automatically collected or generated: When you visit, interact with or use our Services, we may collect or generate certain technical data about you (“Usage Data”). We collect or generate such data either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).
Such Usage Data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device and the activity (clicks and other interactions) of Prospects and Users in connection with our Services. Such data does not enable us to learn a person’s true identity or contact details. We mainly use Usage Data to gain a better understanding on how Prospects and Users typically use and interact with our Services; how we could improve their user experience; to optimize our marketing campaigns and ad management; and to optimize the overall performance of our Services.
- Data received from you:When you contact us or sign up to the Services and create your individual profile (“User Profile”), you may provide is with Personal Data. This includes your name, workplace and position, contact details (such as e-mail, phone and address), account login details (e-mail address and passwords which are automatically hashed – collectively “Account Data”), as well as any other data you choose to provide when you use our Services, contact us, or interact with others via the Services.
- Data received from third parties: we may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or services provides, 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.
2. Data Uses
We process the personal data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services, campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; marketing, advertising and selling our Services; providing customer services and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use Personal Data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
- To facilitate, operate, and provide our Services (Performance of contract with our Customers, to the extent applicable; Legitimate interest to provide and improve our Services);
- To authenticate the identity of our Users, and to allow them access to our Services (Performance of contract with our Customers, to the extent applicable; Legitimate interests to secure our Services and prevent fraud);
- To provide our Prospects, Users and Customers with assistance and support, to test and monitor the Services, or diagnose or fix technology problems (performance of contract with our Customers, to the extent applicable; Legitimate interest to ensure the ongoing availability of our Services);
- To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties (Legitimate interests to improve and enhance our Services);
- To facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively including to provide personalized ads and share data with our authorized service providers to support such activity (Legitimate Interests to enhance engagement with our Services and promote them;
- To contact our Prospects, Users and Customers with general or personalized service-related messages (such as password-retrieval or billing) and promotional messages (such as newsletters, webinars, new features, etc.); to facilitate, sponsor and offer certain events and promotions; and to facilitate our sales and business development operations (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to enhance engagement with our Services; Consent to receive marketing communications);
- 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 (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to secure our services; Legal Obligation to implement appropriate security measures);
- To create aggregated statistical 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 (Legitimate Interests to improve and enhance our Services);
- To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests to dispute resolutions);
- To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of contract with our Customers, to the extent applicable; Legitimate interests to maintain and improve our compliance; Legal obligation, to the extent applicable).
3. Data Location
Your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers (defined below) in the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.
Eloops is headquartered in Israel, a jurisdiction which is considered by the European Commission the Swiss Federal Data Protection and Information Commissioner (FDPIC) and the UK Secretary of State to be offering an adequate level of protection for the Personal Data of of residents of the EEA, Switzerland and the UK, respectively. We transfer personal data from the EEA, Switzerland and the UK to Israel on this basis.
4. Data Retention
We retain Users’ Personal Data in accordance with the instructions of their organization (our Customer), or for as long as their account is active, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.
We keep Prospects’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.
We will also retain your Personal Data for as long as is required 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), in accordance with our data retention policy.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete 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 email at email@example.com.
5. Data Sharing
Legal Compliance: 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 we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing, or when such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.
Service Providers: we engage selected third-party entities to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platform, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems; and our business, legal, financial and compliance 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, supporting and enhancing our Services, and may only use it for such purposes.
Sharing Personal Data with our Customers: We may share the Personal Data of Users with their Customer organization (including data and communications concerning their Services’ user account). In such cases, sharing such data means that other individuals from your organization may receive it on its behalf, and will be able to monitor, process and analyse your Personal Data and associated content. Please note that Eloops is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of your organization, that itself acts as the “Data Controller” of such data (as further described in Section 10 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 Eloops, any of our Users or Customers, or any members of the general public.
Additional Sharing: For the avoidance of doubt, Eloops 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.
6. Cookies and Tracking Technologies
Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “session cookies”. Some last for longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whist we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookie preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you form using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
We engage in service and promotional communications, through email, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. We, or our Customers, may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use
Notifications and Promotional Communications: We may send you notifications concerning messages and other updates in your User account. We may also send you notifications and contact 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 Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Eloops at any time by sending an email to firstname.lastname@example.org, changing your communications preferences in your account, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8. Data Security
We and our Service Providers implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, however, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
9. Data Subject Rights
Individuals have rights concerning their personal data. Please contact us by email at email@example.com If you wish to exercise your rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act (as amended by the CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA) and other similar US states’ laws. Such rights may include, to the extent applicable, the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your Personal Data held with Eloops, or to restrict or object to such Personal Data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to port such Personal Data, or the right to equal services and prices (e.g. freedom of discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.Note that if you are using the Services on behalf of our Customer, your request should be communicated to and through the applicable Customer, and not directly to us.
Please note that once you contact us by e-mail, we 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 4 above.
10. Children’s Privacy
Our Services are 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 Services, we will prohibit and block such use and will make all 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 email at firstname.lastname@example.org.
11. Data Controller/Processor
We are the Controller of our Account Data, Usage Data pertaining to our Users and Prospects, and certain types of Personal Data concerning our Customers, and certain types of User Data; we are the Processor of User Data which we process on behalf of our Customer.
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 Services, to the extent that such laws and regulations apply.
If any of our Users upload or submit User Data or other content to our Services which includes Personal Data (e.g., by submitting additional personal data pertaining to the Customer’s employees), such data will only be processed by Eloops 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 Eloops will process such data on the Customer’s behalf, as its “Data Processor”, in accordance with its reasonable instructions, subject to our Terms, our Data Processing Addendum with such Customer (to the extent applicable) and other commercial agreements. Eloops’ Service Providers shall act as designated Sub-Processors in these instances. The 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).
If you would like to make any requests or queries regarding Personal Data we process as Data Processors, e.g., on your organization’s (our Customer’s) behalf, please contact your organizational admin directly. For example, if you are a User who wishes to access, correct, or delete data processed by Eloops on behalf of a Customer, please direct your request to the relevant Customer (who is the “Data Controller” of such data).
12. Additional Notices
Requirements under US State Privacy Laws: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention (Section 3) and deletion practices (Section 9). We also included information about how we may process your information (in Sections 2 through 7), which includes for “business purposes” under the California Consumer Privacy Act (CCPA), as amended/Virginia Consumer Data Protection Act (VCDPA)/Colorado Privacy Act (CPA) and similar states’ laws, as applicable. We do not sell or “share” your personal information for the intents and purposes of the CCPA or CPRA, nor disclose personal information that we “control” to any third party for their direct marketing purposes. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Section 5 above, if those third parties are our Customers (with respect to Customer Data processed on their behalf), or our authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 5 above. You may also designate, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights be emailing us. Note that we will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights under the law. If you have any questions or would like to exercise your rights under the CCPA/CPRA/VCDPA/CPA or other similar states’ laws, you can contact email@example.com.