Our Commitment to You

Gramatik Ltd. (further “Company”, “us” or “we”) is dedicated to providing users with the highest level of transparency and control over the use of their information. In order for us to provide you with our Services we are required to collect and process certain personal information about you and your activity. By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of this Information.

When you use our Services, you consent to the collection, storage, use, disclosure and other uses of your Personal Data, including cookies, as described in this Privacy Policy. We urge you to read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services.

Effective February 15, 2023

Grounds for Data Collection

You are not legally required to provide us with your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means), but without it we might not be able to provide you with the full range of, or the best experience while using our website(s), mobile application(s) or any other affiliated service (together, the “Services”).

Processing of Personal Data is necessary for the performance of our contractual obligations towards you, for provision and operation of our Services, to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.
Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:

1. Performance of a contract – We will use this basis for processing necessary to make the Services, including support services, available to you, and to send you service communications.
   
   
2. Consent – In limited cases (where you choose to sign up to receive direct marketing emails, and where you accept cookies on our Services) we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details provided below.
   
   
3. Legitimate interests – We will process your Personal Data based on our legitimate interests in maintaining and improving our Services, such as for the purpose of understanding how our Services are used and improving them, our customer service and support operations, and protecting and securing our users, ourselves and our Services.
   
   
4. Compliance with a legal obligation – In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.

What type of data is collected?

1. Personal Data

   
   In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Service, and as otherwise indicated in this Policy. We collect the following Personal Data about you:
   
   

   • Registration information – when you sign up to use our Services, we will collect your name, your mailing address, your email address, your home and work telephone number, information about your company and your position, and similar contact details.
     
     
   • Information received from you – you may choose to provide us Personal Data voluntarily, such as when you contact us (via a contact form on our Services, e-mail or any other channel, including any support services), or when you provide us with your e-mail address when you sign-up to receive our newsletter. When you participate in one of our surveys, we may also collect additional profile information.
     
     
   • When using our Services – our server will collect your IP-address, and information about your general location (such as city and country).
     
     
   • Usage Data – We collect information about how you use our software and plugins, including analytical information of your usage of the software/plugins. Usage Data includes session data, account ID, data about your device and hardware, location data and data about your interactions and engagement with our website and software.
     
     

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific software feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

1. Non-Personal Data

   
   We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:
   
   

   • Technical information – when someone visits, interacts with or uses our Services, including by e-mail or text messages sent to them by us or our Services, we may collect or generate technical data about them. This includes data such as visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, referral URL, time zone, network connection type (e.g., Wi-Fi, cellular), and cookie information. We collect or generate such data either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies. We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services.
     
     

If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

How is that data collected?

We acquire most of the information directly from you through application forms or telephone conversations, and from keeping records of information taken in the course of ongoing customer service.

We may also collect personal information when you use our website, apps or by using cookies on our websites.

Sometimes we may ask for other information voluntarily (including through market research, surveys, or special offers) so that we can improve our services.

How do we use the data we collect?

• Provision of service – we will use your Personal Data for the provision and improvement of our Services, including for support and to respond to your queries.
  
  
• Service announcements – we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.
  
  
• Marketing purposes – we may use your Personal Data (such as your email address or phone number) for marketing purposes. For example, by subscribing to our newsletter you will receive tips and announcements straight to your email account. We may also send you promotional material concerning our services or our partners’ services (which we believe may interest you), including but not limited to, by building an automated profile based on your Personal Data, for marketing purposes.
  
  
• Opt-out of receiving marketing materials –You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us.
  
  

Please note that even if you unsubscribe from our promotional or marketing emails, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us.

Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to provide our Services, fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.

• Analytics, surveys and research – from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Service and think of new and exciting features for our users.
  
  
• Protecting our interests – we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of the Company, its users and/or partners.
  
  
• Enforcing of policies – we may use your Personal Data to enforce our policies, including but not limited to our client agreement.
  
  
• Compliance with legal and regulatory requirements – we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
  
  

Who do we disclose the information to?

• Internal concerned parties – we share your information with companies in our group, as well as our employees, in order to provide you with our services.
  
  
• Business partners – we share your information with business partners, such as storage and analytics providers who help us provide you with our Service. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose.
  
  
• Compliance with laws and law enforcement entities – we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
• Merger and acquisitions – we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your Personal Data in accordance with the terms of this Privacy Policy.
  
  

Transfer of data outside the EEA (for EU data subjects)

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate levels of data protection, or enter into legal agreements ensuring an adequate level of data protection.

How do we store your personal information?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access to your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

We will not keep your personal information for any longer than is required. In many cases, information must be kept for considerable periods of time. However, when we consider that information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.

While we will use all reasonable efforts to safeguard our clients’ personal information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data transferred from you, or to you via the internet.

You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the service, and you do so at your own risk.

Cookies Policy

Cookies help us to offer you an easier and more personalized experience. If you want to ‘opt out’ of the cookies set by our site, you can change the settings on your browser or mobile device to reject all cookies. You can also set your browser settings to receive notification each time a cookie is sent, thus giving the choice whether to accept it or not.

What are cookies?

Cookies are small files that are stored in your browser’s file directory, by the websites you visit. Next time you visit the site, your browser will read the cookie and send the information back to the website or element that originally set the cookie.

What types of cookies do we use?

Our websites use various types of cookies, which allows us to provide you with more personalized and user-friendly experience. Some of them include:

• Cookies to enable navigation through our website and services
• Performance cookies – help improve the use of the Services
• Functionality cookies – save changes in your requested choices
• Marketing cookies – evaluate performance of advertisements and visits on the Services.

How to manage cookies

You can set your browser not to accept cookies. However, in a few cases, some of our website features may not function as a result.

User rights

You may request to:

• Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
  
  
• Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
  
  
• Request rectification of your Personal Data that is in our control.
  
  
• Request erasure of your Personal Data.
  
  
• Object to the processing of Personal Data by us.
  
  
• Request to restrict processing of your Personal Data by us.
  
  

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

Personal Data and other websites

We are not responsible for the privacy policies and practices of other websites even if you accessed a thirdparty website using links from our website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.

Your consent

By submitting any personal information (including, without limitation, your account details) to us you consent to the use of information as set out in this Policy. We reserve the right to amend or modify this Privacy Policy and if we do so we will post the changes on the Website. It is your responsibility to check the Privacy Policy when you submit information to us. Your use of the Website will signify that you agree to any such changes.

How to contact us

If you have any questions regarding this Policy, wish to access or change your information or have a complaint, or if you have any questions about security on our website, you may email us to an email address displayed at our website.