Privacy Policy

At Flarion Inc. (together with its affiliated companies – “Flarion”, “we”, “us” or “our”) we value your privacy. This Privacy Policy ("Privacy Policy") describes how we collect, use, disclose and otherwise process your Personal Information when you (a) visit or interact with our website ("Website"), (b) use or access our products or services ("Services"), (c) communicate or otherwise interact with us, or (d) engage with us through marketing, promotional or business activities or events.

As used herein, "Personal Information" means any information relating to an identified or identifiable individual, including "personal data" and any equivalent term as defined under applicable privacy laws, including the California Consumer Privacy Act, as amended.

We may update this Privacy Policy from time to time to reflect changes in our business, the Website, the Services, applicable law, or our privacy practices. When we make material changes, we will update the "Last Updated" date at the beginning of this Privacy Policy and, where required by applicable law, provide additional notice or obtain consent.

1. Type of Information We Collect

We may collect or obtain the following types of Personal Information:

1. 1.1. your name and business contact information, company affiliation, account credentials and account identifiers;
2. 1.2. information you provide when requesting a demonstration or support;
3. 1.3. IP address, browser type, device information, operating system, network information and unique device or application identifiers; and
4. 1.4. pages viewed, traffic and referral sources, dates and times of access, usage information, system performance metrics, telemetry data, configuration information, execution metadata, diagnostic information, error reports and log files;
5. 1.5. if you use our Services (including on a trial basis), information about your use and configuration of the Services, including software versions, system configuration settings and operational metadata generated through your use of the Services; and
6. 1.6. any other information you choose to provide.

We do not knowingly collect, and request that you do not send or disclose to us, any sensitive personal information (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership).

2. How We Collect Your Personal Information

1. 2.1. We collect Personal Information that you voluntarily provide when you use the Website, register for or use the Services, complete forms (including our "Contact Us" or newsletter/blog subscription forms), request information, book a product demonstration, communicate with us, participate in surveys, webinars, events, or promotions, or otherwise interact with us.
2. 2.2. We collect certain Personal Information automatically when you visit or use the Website or Services through cookies, similar technologies and other technical means, as described below.
3. 2.3. We may also receive Personal Information from third parties, including our business partners, service providers, event organizers, marketing partners, publicly available sources, professional networking platforms (such as LinkedIn), and other sources that help us identify potential customers, business partners, or employment candidates.
4. 2.4. Additional Disclosures for Individuals Located in the United States. The following additional provisions apply to you when you are physically located in the United States. When you visit the Website, and subject to your cookie preferences, we use a visitor identification service provided by GetEmails LLC (d/b/a Retention and RB2B). This service uses cookies and similar technologies on the Website to associate your visit with personal information it holds or obtains from its data partners, including by association with your email or online profiles, including, for example, your name, job title, email, phone number, company and professional profile. We (or service providers on our behalf) may then send communications and marketing to these emails or profiles. You can opt out at https://app.retention.com/optout, by rejecting marketing cookies in our cookie preferences, or by enabling a Global Privacy Control signal in your browser.

3. How We Use Your Personal Information (and our legal basis)

1. 3.1. We use Personal Information to:
   1. 3.1.1. Provide, operate, maintain, secure, and improve the Website and Services, including user authentication and account administration;
   2. 3.1.2. Provide customer support; respond to inquiries; and send service, administrative and promotional updates;
   3. 3.1.3. Detect, investigate, and prevent fraud, security incidents, or unlawful activity; enforce our agreements; and comply with our legal obligations;
   4. 3.1.4. Monitor usage trends; personalize experiences; and optimize the performance of our Services and the Website; and
   5. 3.1.5. Identify businesses and individuals who have shown interest in our Services, and prioritize our sales and marketing activities.
2. 3.2. Where permitted by applicable law, we may also use aggregated, anonymized or de-identified information for analytics, product development, research, benchmarking and other lawful business purposes. Such information does not identify any individual.
3. 3.3. We process Personal Information only where we have an appropriate legal basis, including performance of a contract, our legitimate interests, your consent, compliance with legal obligations, or the establishment, exercise or defense of legal claims.
4. 3.4. When we process Personal Information on behalf of customers in connection with the Services, we act solely as a processor or service provider (as applicable), and the customer acts as the controller or business (or their equivalent under applicable law). Such processing is governed by the applicable agreement between Flarion and the customer, including any applicable data processing agreement ("DPA"). This Privacy Policy applies only to Personal Information that Flarion collects and processes for its own business purposes. To the extent of any conflict between this Privacy Policy and an applicable DPA with respect to Personal Information processed on behalf of a customer, the DPA will prevail.

4. How We Share Your Personal Information

1. 4.1. We may share Personal Information with our affiliated companies for the purposes described in this Privacy Policy.
2. 4.2. We may share Personal Information with third-party service providers (“Service Providers”) that perform services on our behalf or support our business operations, including providers of hosting, cloud infrastructure, communications, analytics, security, customer support, marketing, professional advisory and other business services. Such Service Providers are authorized to access and use Personal Information only as necessary to provide services to us or as otherwise permitted under our agreements with them.
3. 4.3. We may disclose Personal Information if we believe in good faith that such disclosure is necessary or appropriate to:
   1. 4.3.1. comply with applicable law, regulation, legal process or a request from a governmental authority;
   2. 4.3.2. enforce our agreements or protect our rights, property or interests;
   3. 4.3.3. detect, investigate or prevent fraud, security incidents or other illegal activity; or
   4. 4.3.4. protect the rights, property or safety of Flarion, our customers, users or others.
4. 4.4. We may disclose or transfer Personal Information in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, bankruptcy or other corporate transaction. We will notify you of any material changes affecting the processing of your Personal Information.
5. 4.5. We may share your Personal Information with third parties where you have directed us to do so or otherwise consented to such disclosure.
6. 4.6. We make information about your visits to the Website, including cookie and device identifiers, pages viewed and referral sources, available to our visitor identification provider described in Section 2.4. The provider may use this information for its own purposes, including to maintain and improve its data. Under certain US state privacy laws, this may be considered a "sale" or "sharing" of Personal Information.

5. Data Location and International Transfers

1. 5.1. We and our authorized Service Providers process Personal Information in the United States of America, the EU, the UK, Israel, Japan and other locations, as reasonably necessary for the proper performance and delivery of our Website and its Services.
2. 5.2. To the extent we transfer Personal Information originating in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland to a country that has not been recognized as providing an adequate level of data protection under applicable law, we rely on appropriate transfer mechanisms. You may request further information about the transfer mechanisms we rely on by contacting us at privacy@flarion.io.

6. Cookies and Similar Tracking Technologies

We use cookies and similar technologies to operate the Website and Services, remember user preferences, analyze usage, improve functionality, maintain security, and, where permitted, support our marketing activities. Certain cookies are necessary for the operation of the Website and Services, while others are used only with your consent where required by applicable law. For more information about the cookies and similar technologies we use, the purposes for which they are used, and how you can manage your preferences, please see our Cookie Notice (available on our Website) which forms part of this Privacy Policy.

7. Third Party Websites and Services

Our Website or Services may contain links to third-party websites or integrate with third-party services. Your interactions with such third parties are governed by their own terms and privacy policies, and not by this Privacy Policy. We encourage you to review their privacy policies before providing them with your Personal Information.

8. How We Protect and Retain Your Personal Information

1. 8.1. We implement appropriate organizational and technical security measures to protect your Personal Information. These measures are designed to minimize the risks of theft, damage, loss, or unauthorized access and use. However, please be aware that regardless of the security measures used, we cannot and do not guarantee that our Website and Services will be completely immune from wrongdoing, malfunctions, unlawful interception, or misuse.
2. 8.2. We retain Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide the Website and Services, comply with our legal, regulatory and contractual obligations, resolve disputes, enforce our agreements, and establish, exercise or defend legal claims. In determining the appropriate retention period, we consider the nature and sensitivity of the Personal Information, the purposes for which it was collected, applicable legal requirements, and our legitimate business needs.
3. 8.3. Except as required by applicable law or our contractual obligations, we are not required to retain Personal Information for any particular period and may securely delete or anonymize it when it is no longer needed for the purposes described in this Privacy Policy.

9. Marketing Communications

We may send you service, marketing and/or promotional communications (including updates on new features, offerings, and events) via email, SMS/text, push notifications and/or other digital messaging channels. These may be delivered directly, through the Website, directly to you or your device, or via our marketing campaigns on other platforms. You can opt out of promotional and marketing messages at any time by emailing privacy@flarion.io or following the “unsubscribe”, “stop”, or “opt-out” instructions in the communication.

Text messages (SMS). If you give us your mobile number and tick the box to receive text messages, for example a reminder for a meeting you booked, we use your number only to send those messages. Message frequency is shown where you opt in; message and data rates may apply. Reply STOP to opt out or HELP for help. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging opt-in data and consent are excluded from all sharing described in this Privacy Policy and will not be shared with any third parties.

10. Your Privacy Rights

The following rights (which may be subject to certain exemptions or limitations in accordance with applicable law) shall apply to certain individuals (some of which only apply to individuals protected by specific laws).

1. 10.1. You have the right to withdraw consent to the processing, where consent is the basis of processing.
2. 10.2. You have the right to access the Personal Information that we hold and request further details about how we process it.
3. 10.3. You have the right to demand rectification of inaccurate Personal Information about you. We will promptly correct any information found to be incorrect.
4. 10.4. You have the right to object to unlawful data processing.
5. 10.5. You have the right to the erasure of past data about you (your “right to be forgotten”).
6. 10.6. You have the right to demand that we restrict the processing of your Personal Information; if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your Personal Information is inaccurate.
7. 10.7. You have the right to data portability of Personal Information concerning you that you provided us in a structured, commonly used, and machine-readable format.

For US residents, this Section 10 and Section 1 above constitute our Notice at Collection under applicable US state privacy laws. Depending on your jurisdiction, your rights include the right to request access to, correction of, or deletion of your Personal Information, as well as the right to opt out of the "sale" or "sharing" of your data for cross-context behavioral advertising. Except as described in Section 4.6, we do not sell your Personal Information or share it for cross-context behavioral advertising, and in no case do we process sensitive personal information. You may opt out of the sale or sharing described in Section 4.6 by rejecting marketing cookies in our cookie preferences or by contacting us at privacy@flarion.io. We recognize and honor Global Privacy Control (GPC) opt-out preference signals. If your browser transmits a GPC signal, we will treat it as a valid request to opt out of the sale or sharing of your Personal Information. You may exercise these rights by contacting us at privacy@flarion.io, and we will verify your request using your account credentials or business email.

You can exercise your rights under this Section by contacting us at privacy@flarion.io. or by mail or courier to: Flarion, 10 Odem Street, Gadera, Israel. We will not discriminate against you for exercising any privacy rights available under applicable law. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Depending on your location and applicable law, you may also have the right to appeal our decision regarding your privacy request.

11. Minors

We do not knowingly collect Personal Information from minors and do not wish to do so. If we learn that a person under the age of 16 is using the Website, we will attempt to prohibit such use and will make our best efforts to promptly delete any Personal Information stored with us with regard to such person. If you believe that we might have any such data, please contact us by e-mail at privacy@flarion.io

12. Questions; Contact

If you have any questions regarding this Privacy Policy, or if you have any concerns regarding how we process your Personal Information, please contact us at privacy@flarion.io.  If you are a GDPR or UK GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority, or the UK’s Information Commissioner’s Office, as appropriate

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