Approve.com Privacy Policy

Last Updated: June 8, 2020

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Swiftt Development Ltd.and its affiliates (together, “Approve.com” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following 9 use cases:

When you make use of, or interact with, our Website https://www.approve.com/ (“Website”)
When you contact us (e.g. customer support)
When you make use of our Service
When you log-in and make use of the Services
When an administrator user creates additional users
When a user or customer uploads vendor’s data to the Service
When we make vendor’s data available to Customers
When a vendor creates its page
Marketing data, business cards, social media interactions (e.g., Facebook, LinkedIn, Twitter)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or means of enforcement.

Table of Content

What information we collect, why we collect it, and how it is used
How we protect and retain your information
How we share your personal data
Additional information regarding transfers of personal data
Your privacy rights
Use by children
Interaction with third party products
Log files
Analytic tools
How to contact us

Note that in certain contexts some of the data or further additional data may be processed by us in accordance with a data processing agreement with the relevant controller.

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

A. When you make use of, or interact with, our Website (e.g. request a demo)

i. Specific personal data we collect: Full name, email address, company name, phone number.

ii. Why is the personal data collected: To offer our Service; share marketing communications.

iii. Legal basis (GDPR only, if applicable):
* Processing is necessary in order to take steps at the request of the data subject prior to entering into a contract
* Legitimate interest (providing you with a demo of our service)
* Consent

iv. Third parties with whom we share your personal data; and for what purpose:
3rd party platforms, such as Salesforce, Hubspot, Google Analytics, Intercom, AWS, Looker.

v. Retention period: Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

vi. Consequences of not providing the personal data: Cannot enter a sales process or offer our Service.

B. When you contact us (e.g. customer support)

i. Specific personal data we collect: Full name, email address, company name, phone number, reason of inquiry, other information you choose to share.

ii. Why is the personal data collected: To process and answer questions; provide support (e.g., to solve problems, bugs or issues) and handle your complaints and/or feedback.

iii. Legal basis (GDPR only, if applicable):
* Processing is necessary for the performance of a contract to which the data subject/our customer is a party or in order to take steps at the request of the data subject prior to entering into a contract
* Legitimate interest (e.g. to respond to a query sent by you)

iv. Third parties with whom we share your personal data; and for what purpose:
3rd party platforms, such as Salesforce, Intercom, Logz.io, Sentry.

vi. Consequences of not providing the personal data: Cannot assist you and respond your query, Cannot provide support and handle your complaints and/or feedback.

C. When you make use of our Services, or when we create your account

i. Specific personal data we collect: Full name of employees, email addresses, company name, roles, departments, employees’ photos.

ii. Why is the personal data collected:

To create an account as an administrator user
To create regular users and to manage the options and restrictions for each user
To provide the Services and the features and functionality available only for registered users
To improve the Services
To provide you with a better user experience

iv. Third parties with whom we share your personal data; and for what purpose:
3rd party platforms, such as AWS (including Fargate, S3), Atlas by MongoDB, Mixpanel, Intercom, Logz.io, Sentry, Elastic Search, Neo4J.

vi. Consequences of not providing the personal data: Cannot create an account, administrator user, regular user accounts, manage users permissions, product improvement, optimize user experience.

D. When you log-in and make use of our Service

i. Specific personal data we collect: IP address, Cookies and analytical information.

ii. Why is the personal data collected: To grant you access to our Service and allow you to make use of it; improve the product.

iii. Legal basis (GDPR only, if applicable):
* Processing is necessary for the performance of a contract to which the data subject/our customer is a party
* Legitimate interest (e.g. allow you make use of our Service)

vi. Consequences of not providing the personal data: Cannot grant access to the Service or allow use of it.

E. When an administrator user creates additional users’ accounts

i. Specific personal data we collect: Full name of employees, email addresses, company name, roles, departments, employees’ photos.

ii. Why is the personal data collected: To grant you access to our Service and allow you to make use of it; improve the product.

vi. Consequences of not providing the personal data: Cannot grant access to the Service or allow use of it.

F. When a user or customer uploads vendor’s data to the Service

i. Specific personal data we collect:
* When the vendor is a legal entity, we collect some information on contact persons: Full name, email addresses, phone number, company name, roles, departments, contact’ photo
* When the vendor’s data includes individual’s Personal Data, we also collect: Social media accounts, field of occupation, bank and payment details, other information a user decides to share

Note that this information will be shared with other users of the Service.

ii. Why is the personal data collected: To grant you access to our Service; allow you to make use of vendor related features; improve the product.

vi. Consequences of not providing the personal data: Cannot enable all vendor related features.

G. When we make vendor’s data available to Customers

i. Specific personal data we collect:
When the vendor’s data includes individual’s Personal Data, we collect: Full name, email address, phone number, job position, company name, social media accounts, field of occupation, bank and payment details, other information a user decides to share

ii. Why is the personal data collected: To grant you access to our Service; allow you to make use of vendor related features; improve the product.

vi. Consequences of not providing the personal data: Cannot enable all vendor related features.

H. When a vendor creates its page

Note that this information will be shared with other users of the Service.

ii. Why is the personal data collected: To process vendor’s input or request; grant you access to our Service; allow users to make use of vendor related features; improve the product.

vi. Consequences of not providing the personal data: Cannot enable all vendor related features.

I. Marketing data, business cards, social media interactions (e.g., Facebook, LinkedIn, Twitter)

i. Specific personal data we collect: Full name, email address, company name, phone number, social media accounts, role, other information you decide to share.

ii. Why is the personal data collected: To offer our Service; share marketing communications.

iv. Third parties with whom we share your personal data; and for what purpose:
3rd party platforms, such as Salesforce, Hubspot, Google Analytics, Intercom.

vi. Consequences of not providing the personal data: Cannot enter a sales process or offer our Service.

Finally, please note that some of the above mentioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually.

3. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
- To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
- If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
- In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
- Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
- Internal transfers: Transfers within the Approve.com group will be covered by an internal processing agreement entered into by members of the Approve.com group (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
- External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.

5. YOUR PRIVACY RIGHTS: HOW TO DELETE YOUR ACCOUNT

Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
You have the right to object, to or to request restriction, of the processing;
You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
You have the right to object to profiling;
You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at info@approve.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Deleting your account: Should you ever decide to delete your account, you may do so by [emailing info@approve.com].

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@approve.com.

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

9. ANALYTIC TOOLS

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
Mixpanel. We collect personal information such as your email address and your user activity through Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.

We reserve the right to remove or add new analytic tools.

10. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at: info@approve.com.