1. General
   • This is the privacy policy (“Policy”) of Flexiwan Ltd. (“Company”, “We”, “Us”, “Our”).
   • The Company is committed to protecting your privacy. As part of this commitment, it is important for Us that you are aware of what information We (or others on Our behalf) collect about you, when We collect information about you, and how We use such information.

2. To what does this Policy apply?
   • This Policy describes the types of information that We collect about natural persons, when We collect it, how We use it, share it with third parties, maintain it, etc.
   • In this Policy, any reference to “Personal Data” is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We have access to.

3. When do We collect information about you?
   • We may collect Personal Data about you in the following circumstances:
     • When you access or use the Website and the services contained therein (the “Services”); and
     • When you interact with Us in any manner, including through Our customers service.
   • You are under no legal obligation to furnish any information about you, and the furnishing thereof is at your discretion and at your own free will. However, if you do not furnish certain information about you, We shall not be able to provide you with some of Our services and/or products.

4. What types of information do We collect?
   • We (or others on Our behalf) may collect the following types of Personal Data about you:
     • Website usage information: this information includes online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, software crash reports and type of browser used, information regarding the device you used. If you subscribe to receive updates and/or newsletters from Us through the Website, you shall provide Us with your email address or other contact information. Some of this information may not identify you personally, and therefore not constitute Personal Data.
     • Communication information: when you contact Us, including via Our Website and/or social media networks, you may provide Us with your name, certain contact information (such as email address, telephone number and certain business related information) and the content of your communication with Us. Moreover, if you contact Us telephonically, Our customers service representatives may record and/or document in writing your calls.
   • You are responsible for ensuring the accuracy of the information that you provide Us (or others on Our behalf) with. Inaccurate information will affect Our ability to provide you with Our Services and products, as well as Our ability to contact You as contemplated in this Policy.

5. How do We use Personal Data?

We may use Personal Data about you for the following purposes:

• To operate the Website and provide the Services;
• To personalize your experience when using the Website and the Services;
• To contact you for the purpose of operational requirements;
• To respond to your queries, requests and/or complaints, and to provide you with customer support services;
• To send you marketing materials;
• To analyze and improve Our products and Services (including, but not limited to, the Website), as well as to offer new ones;
• To analyze the effectiveness of any of Our marketing and advertising campaigns and activities;
• To perform and maintain various activities supporting the offering and provision of Our products and services, including, but not limited to, the Website (such activities include back office functions, business development activities, strategic decision making, financing management, etc.);
• To protect Our and third parties’ interests, rights and assets, including initiation or exercise or defense of legal claims;
• To fulfil Our legal or regulatory requirements.

6. Sharing of Personal Data
   • We will not disclose Personal Data about you to third parties except as detailed in this Policy.
   • We may transfer Personal Data to entities that control Us, entities that are under Our control and/or to entities under common control or ownership with Us, as shall be from time to time (collectively the “Group”). Such entities may use the Personal Data to support the needs of the Group.
   • We may share Personal Data about you with the following third parties or for the following purposes:
     • Upon your consent or instruction;
     • Third parties providing Us services related to the offering of Our Services and products (including the Website);
     • In the event that We sell, assign or transfer some or all of Our business or assets to a successor or acquirer, or if We are acquired by or merge with a third party, or if We file for bankruptcy or become insolvent, or any other situation where Personal Data may be sold, assigned or transferred to a successor or acquirer;
     • To protect Our rights, property and interest or those of third parties;
     • To fulfil Our legal or regulatory requirements or to comply with a court order.

7. Transfer of Personal Data abroad

We may transfer Personal Data about you outside the jurisdiction which you are a resident of and store it in other jurisdictions and countries; the data protection and other laws of these jurisdictions or countries may not be as protective to Personal Data as those in the jurisdiction which you are resident – in these instances, We will take steps to ensure that an appropriate level of protection is given to your Personal Data.

8. Retention of Personal Data

We will retain Personal Data about you only for as long as necessary for the fulfillment of the purposes for which such Personal Data is collected. We may retain Personal Data about you for longer periods, if We find it necessary to comply with legal requirements applicable to Us.

9. Choice / Opt-Out
   • By agreeing to this Policy, you hereby allow Us to provide you with communications from Us, as well as from third parties, either in connection with the Services or in connection with other products and services (including, but not limited to, commercial matters and offers). You hereby acknowledge and consent to the sending of such communications, and will not argue that such activity amounts to sending of unsolicited communications. You also acknowledge that We are not responsible for any communication sent to you by third parties, their content and method of distribution.
   • You may opt-out from receiving communications from Us by sending a blank e-mail to Us with the word “Remove” to [email protected] and/or by clicking on the unsubscribe link available in Our e-mails sent to you.

10. Cookies
    • We (or others on Our behalf) use various technologies to collect information when you interact with Our Website, including cookies and web beacons. Cookies, which are small text files that are placed on your computer or equipment when you visit certain online pages, track your activities, record your preferences, and make the Website more responsive to your needs by delivering a better and more personalized experience to you. The cookies are stored on your computer and/or other equipment and are used by Us to help track your clicks and pass information as you go through the Website and can allow Us to associate navigational information from browsing visits with Personal Data you provide via the Website. Web beacons are graphic images that are placed on the Website or in an email that is used to monitor your behavior while visiting the Website or sending the email and are often used in combination with cookies.
    • You can change the privacy settings in the browser that you use, delete the existing cookies, prevent the creation of cookies or click the setting that enables you to accept or deny the creation of a cookie every time that a cookie is detected. If you opt to not accept cookies and/or cancel your acceptance of cookies, you will be limiting your ability to enjoy all of the interactive features on the Website.

11. Security

We have implemented suitable security policies, rules and technical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction.

12. Disclaimer

We cannot guarantee, nor do We represent, that there will be error-free performance regarding the privacy of your Personal Data, and We will not be liable for any indirect, incidental, consequential, or punitive damages relating to the use or release of Personal Data about you including, but not limited to, disclosure of Personal Data due to errors in transmission, unauthorized third-party access, or other causes beyond Our reasonable control.

13. Links to Other Websites
    • The Website may contain links to websites and/or applications of third parties. Other websites and applications may also reference or link to Our Website. We do not control such websites and applications, nor the collection and/or processing of Personal Data about you by such websites and applications, and thus We are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and/or applications.
    • Whenever you access such third parties’ websites and/or applications, We recommend that you carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about you.

14. Changes to the Policy

We may change this Policy in Our sole discretion at any time. Any revisions to this Policy will be posted as an updated version accessible via the Website home page. We recommend that you revisit this Policy regularly so as to be kept apprised of any such changes.

15. Contact Us

For any queries relating to this Policy and data protection please contact Us at [email protected] or via the communication details appearing in the “Contact Us” section on the Website https://flexiwan.com/contact/.

Last updated: November 27, 2019.