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Platform Privacy Policy

January 2026
 

Introduction

Welcome to the ClearMash Platform (the "Platform"). The Platform is a web-based, AI-driven knowledge-management platform that turns static company knowledge bases into actionable guidance, providing workflows, visual step-by-step instructions and intelligent alerts to shorten resolution times, boost compliance, and improve customer satisfaction. The Platform is owned and operated by ClearMash Solutions Ltd. ("ClearMash" or "we", "us", "our"). Use of the Platform is subject to our general Terms of Use.

We are committed to complying with applicable data protection laws. This Privacy Policy (“Policy”) explains how we collect and use your information when you access and use the Platform.

The Platform is not intended for users under the age of 18. We do not knowingly collect information from children under the age of 18 or knowingly allow minors under the age of 18 to use the Platform.

This Policy may be amended from time to time. We will post any change to this Policy on our Platform a reasonable time in advance of the effective date of the change, and we will also make efforts to proactively notify you of the changes if we have your email address.

 

Contact Us

If you have any questions, comments or concerns regarding this Policy or our processing of your personal information, please contact us through our online contact form or email us at legal@clearmash.com.

 

What We Collect and Why

Scenario

Purposes

Categories of information processed

Creating your Platform user account

Allowing you to use the Platform and its features, customizing the Platform to your preferences

We create your profile on the Platform per your organization's request. In this process, we collect and process your name, username, mobile phone number and email address. Your organization may also provide us with information about your department and role.

You may also decide to provide us your profile picture, and any preferences in relation to your use of the Platform (e.g., interface language, favorite pages, system notifications, etc.).

Your activity on the Platform

Providing you with the functionalities of the Platform; customizing the Platform to your preferences; improving and enhancing the Platform

The results of the knowledge tests you take; the contents of any ideas and/or suggestions in relation to the content available on the Platform that you submit through the Platform; the contents of the messages you share with other users in your organization through the Platform; the contents of your conversations with our AI features.

Please use discretion when deciding which information to share through the Platform. YOU ARE SOLELY LIABLE FOR PROTECTING THIRD PARTIES’ AND YOUR OWN PRIVACY, AND FOR OBTAINING THE PRIOR CONSENT OF INDIVIDUALS WHOSE PERSONAL INFORMATION YOU INCLUDE IN ANY MESSAGES OR INFORMATION YOU SHARE THROUGH THE PLATFORM. WE WILL NOT BEAR LIABILITY FOR ANY DAMAGES THAT YOU OR OTHERS MIGHT INCUR AS A RESULT OF THE INCLUSION OF PERSONAL INFORMATION IN THE TEXT YOU SUBMIT.

Please note that when you use our AI features, the information you receive is generated by AI models and not by humans. The AI features are intended for general informational and assistance purposes only and should not be relied upon as a substitute for professional advice, judgment, or decision-making.

Providing us with Testimonials

The operation of our business

You may provide us with your written, recorded or videotaped review or feedback about the Platform ("Testimonial").

Please use discretion when deciding which information to share in your Testimonial.

Contacting us through our online contact form

Responding to your inquiries; maintaining our customer relations with you; the operation of our business

Your username, email address, and the subject and content of your inquiry.

Use of cookies and analytics on the Platform

Operating the Platform; customizing the Platform to your preferences and needs; the operation of our business

Your organizational affiliation; information concerning your use of the Platform, e.g., IP address from which you accessed the Platform, time and date of access, type of device and browser used, language used, links clicked via a mouse or a touch screen, and actions taken while using the Platform.

You do not have a legal obligation to provide the above Information; however, if you choose to not share this information with us, we may not be able to manage your user account on the Platform, allow you to use various Platform functions, consider your ideas and suggestions, or respond to your questions and inquiries.

 

Methods and Sources for Collecting Your Personal Information

We collect the personal information from several sources:

   From your organization, for the purpose of creating your user account and for the ongoing operation of our Platform.

   Directly from you when you use the Platform (e.g., when you chat with our AI chatbot), provide us with Testimonials, or when you contact us.

   Through the device you use to access our Platform.

 

Sharing Your Personal Information

We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.

Scenario

Purposes

Examples of third parties involved

We will share your information with our service providers who assist us with the internal operations of the Platform. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes

Operating the Platform and managing our business

An updated list of our service providers may be found here

We will share your information with your organization

Maintaining our business relationship with your organization

Your organization

We will share your organizational chat messages and any ideas or suggestions you submit in relation to the Platform's content, with other users of the Platform within your organization

Providing you with the functionalities of the Platform; operating our Platform

Other users of the Platform within your organization

We will share your Testimonial (or parts of it) on our website and through our marketing materials

The operation of our business

Users of our website, prospective customers and investors

If you abused your rights to use the Platform or violate any applicable law while engaging with us

Responding to, handling, and mitigating suspected violations of law in connection with our business

Competent authorities, legal counsels, and advisors

If a judicial, governmental, or regulatory authority requires us to disclose your information

Complying with a binding request from a competent authority

Competent authorities

If the operation of the Platform or our business is organized within a different framework, or through another legal structure or entity

Enabling a structural change in the operation of the Platform and our business.

The target entity of the merger or acquisition, legal counsels, and advisors.

The third parties with whom we share information as described above may be located outside your jurisdiction, and subject to the privacy protection laws of these jurisdictions. If we transfer your personal information to other jurisdictions, we will do so in accordance with applicable law.

Cookies

We use cookies on the Platform in accordance with our cookies policy.

Data Retention and Security

We retain your information for as long as you are an active user of the Platform, and thereafter as needed for record-keeping purposes.

We will retain your information for as long as you are an active user of the Platform (or as otherwise requested by your organization), and for 30 days thereafter. Following that period, we will retain a backup copy of your personal information for two years, unless your personal information is required for a longer period to comply with our legal obligations, resolve disputes, establish and defend legal claims, and enforce our agreements.

We implement measures to secure your information

We implement measures to reduce the risks of damage, loss of information, and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, there is no guarantee that it will be immune from information security risks.
 

International data transfers

We may transfer, store, and process your personal data in countries other than your own, such as Israel.

The countries to which we transfer your personal data may provide a level of data protection that does not meet the level of protection provided by your country. In such cases, we take the appropriate safeguards required by applicable law to ensure that your personal data remains protected, including the implementation of standard contractual clauses or any other lawful transfer mechanisms recognized by applicable data protection legislation.

Your Rights

ClearMash Solutions Ltd. is the controller of the databases containing your personal information in relation to Testimonials and reviews and cookies. Our address is HaNofar 2, Suite 1003, Raanana, Israel.

Your organization is the controller of any other personal information processed when you use our Platform, as described herein

As a user of our Platform, you have the following rights in relation to your personal information:

   Right to review your information. You have the right to review, either by yourself or through an authorized representative or a guardian, any information we have stored about you in our databases.

   Right to request to rectify your information. If, upon reviewing your information, you find it to be incorrect, incomplete, or outdated, you have the right to ask us to rectify or delete it. We will inform you within 30 days whether we can comply with your request.

   Right to have your personal information deleted, under certain circumstances, such as when the information is no longer necessary for the purposes for which it was collected.

Please note that any changes to your personal data that is controlled by your organization (including its deletion) will be subject to your organization's review and approval.

Additional Information for Individuals in EEA And UK
 

Data Controller. The controller of your personal data we process when creating your user account on the Platform, through your activity on the Platform and when handling your inquiries, is your organization.

The controller of your personal data we process through your activity on the Platform, when you provide us with Testimonials and the data collected through cookies, is ClearMash Solutions Ltd. Our address is HaNofar 2, Suite 1003, Raanana, Israel.

International data transfers. To facilitate processing your information through the Platform (including by our service providers), we will transfer your information to and within countries outside the EU or the UK, such as Israel. We do so under an adequacy decision or under the terms of a data transfer agreement which contains standard data protection contractual clauses with adequate safeguards determined by the EU Commission and the UK Information Commissioner’s Office.

Legal basis for processing your personal data. We process your personal data under our role as data controller based on the following legal bases:

Purpose or Scenario

Legal Basis

Your activity on the Platform

Our legitimate interest in improving and enhancing the Platform.

Providing us with Testimonials

Our legitimate interest in the proper operation of our business.

Use of strictly necessary cookies on the Platform

Our legitimate interest in the proper operation of the Platform.

Use of optional cookies on the Platform

Your consent.

Analytics

Our legitimate interest in the proper operation of the Platform and our business.

Sharing your Testimonial on our website and through our marketing materials

Our legitimate interest in the proper operation of our business.

Responding to, handling, and mitigating suspected violations of law in connection with our business

Our legitimate interest in defending and enforcing against violations and breaches that are harmful to our business.

Complying with a binding request from a competent authority

Our legitimate interest in complying with mandatory legal requirements imposed on us.

Enabling a structural change in the operation of the Platform and our business

Our legitimate interest in our business continuity.

The legal bases for processing your personal data under our role as data processor are determined by your organization.

Data subject rights. If you are in the EEA or the UK, you have the following rights:

   Right to Access and receive a copy of your personal information that we process.

   Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.

   Right to Data Portability, that is, to receive the personal information that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another person or entity. Where technically feasible, you have the right to have your personal information transmitted directly from us to the person or entity you designate.

   Right to withdraw your consent to processing your personal information, easily and at any time, if the basis for our processing is your consent. We may continue to process personal information with respect to which your consent is not necessary. Withdrawing your consent will not affect the lawfulness of the processing we carried out based on your consent before such withdrawal.

   Right to Object to our processing of your personal information based on our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to process such personal information for the establishment, exercise, or defense of legal claims.

   Right to Restrict us from processing your personal information (except for storing it): (a) if you contest the accuracy of the personal information (in which case the restriction applies only for a period enabling us to determine the accuracy of the personal information); (b) if the processing is unlawful and you prefer to restrict the processing of the personal information rather than requiring the deletion of such data by us; (c) if we no longer need the personal information for the purposes outlined in this Policy, but you require the personal information to establish, exercise or defend legal claims; or (d) if you object to our processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).

   Right to be Forgotten, under certain circumstances, such as when you object to our processing of your personal information based on our legitimate interest and there are no overriding legitimate grounds for the processing. However, notwithstanding such a request, we may still process your personal information if it is necessary to comply with our legal obligations, or for the establishment, exercise, or defense of legal claims. If you wish to exercise any of these rights, please contact us through the channels listed in this Policy.

We do not implement automated decision-making mechanisms in the Platform.

When you contact us with a request, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. If we are not able to provide you with the information that you have asked for, we will explain the reason.

Please note that any changes to your personal data that is controlled by your organization (including its deletion) will be subject to your organization's review and approval.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority in the Member State of your residence, place of work, or place of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

If you are in the UK, you can lodge a complaint to the Information Commissioner’s Office (ICO) pursuant to the instructions provided here.
 

Additional Information for Individuals in the United States

ClearMash Solutions Ltd. is providing the following additional information to its clients residing in the United States, pursuant to applicable state privacy laws in the U.S.

We do not sell your information to any third party, or share it for cross-context behavioral advertising. Furthermore, we do not collect, use or share sensitive information.

We keep the personal information specified below as long as necessary to operate the Platform. Following that period, we shall ensure that the information is not accessed, other than in extraordinary events such as legal disputes.

Categories of personal information we collect and process and their sources

Below are the categories of personal information we have collected and processed over the past 12 months, and the source of that information.

Categories of personal information

Details of the personal information that was collected

Sources of information

Identifiers

Name, account name, mobile phone number and email address; IP address

1.   From your organization.

2.   Directly from you.

3.   Through the device you use to access our Platform.

Professional or employment-related information

The organization you work for; your organizational affiliation; the results of the knowledge tests you take

Other information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Your inquiries and questions; your content ideas and suggestions; the contents of the messages you share with other users in your organization; the contents of your conversations with our AI chatbot; your preferences in relation to your use of the Platform

Visual or audio information

Your profile picture (if you chose to provide it); your Testimonial

Internet or other electronic network activity information

Data collected by cookies; Your activity on the Platform

 

Business purposes for the collection of personal information

Categories of personal information (per the table above)

Business purposes

Identifiers

Professional or employment-related information

Other information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Visual information

Internet or other electronic network activity information

1.   Providing services through the Platform.

2.   Debugging to identify and repair errors that impair existing intended functionality.

3.   Detecting and preventing security incidents.

4.   Undertaking activities to verify or maintain the quality or safety of the Platform and to improve, upgrade, or enhance the Platform.

Disclosures to third parties

Below are the categories of personal information we shared with third parties over the past 12 months and the categories of third-party entities we share them with.

Categories of personal information (per the table above)

Categories of entities we give the information to, and why

Identifiers

Professional or employment-related information

Other information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Visual information

Internet or other electronic network activity information

   Our service providers, who will use it only as necessary to assist us in the internal operations of our business and the Platform, and not for their own promotional purposes.

   Your organization.

   Other users of the Platform within your organization.

   Competent authorities, legal counsels, and advisors, if you abused your rights to use the Platform or violated any applicable law in the course of doing business with us.

   Judicial, governmental, or regulatory authority if they require us to disclose your information.

   Target entity of a merger or acquisition, legal counsels, and advisors If the operation of the Platform or our business is organized within a different framework, or through another legal structure or entity.

Your rights

The Right to Know. You have the right to know whether we are processing your personal information. If we are, you have the right to know the following information, which we will provide to you after we receive your request and verify your identity:

   The categories of personal information we collected about you.

   The categories of sources from which the personal information was collected.

   The purposes for which we collect personal information.

   The categories of third parties with whom we share personal information.

   The specific pieces of personal information we collected about you.

The Right to Obtain a Copy of Your Personal Information. If your data is available in a digital format, you have the right to obtain a copy of the personal information we hold about you in a portable and readable format (to the extent this is technically feasible).

The Right to Delete Your Personal Information. In some cases, state privacy laws provide for the right to request the deletion of your personal information.

The Right to Correct Inaccurate Personal Information. Once we receive a request from you to correct your data and verify your identity, we will examine the veracity of the corrected information you provided, consider your request to correct, and inform you of our decision.

To establish the veracity of the personal information as per your request, we will consider all circumstances pertaining to the personal information for which correction is requested. We may also require you to provide documentation in support of your request to correct the personal information.

The Right to Opt-Out of Processing for Solely Automated Profiling. You have the right to opt-out of solely automated processing of your personal information to evaluate, analyze, or predict your personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, where that processing is done in furtherance of a decision that produces a legal or similarly significant effect on you.

The Right to Non-Discrimination as a Result of Exercising Your Rights. You have the right not to be discriminated against by us for exercising the rights granted to you under applicable law. If you exercise your rights, we cannot:

   deny you services.

   charge different prices or fees for services, including through discounts, benefits, or fines.

   provide you with a different level or quality of services.

   propose that you receive different prices or tariffs for services.

Please note that we may charge a different fee or provide a different level or quality of services if the difference is reasonably related to the value we gain from your personal information.

Filing Requests

Should you wish to exercise your rights under applicable laws as specified above, please contact us by email at legal@clearmash.com.

To verify your identity, we will ask you to provide additional information through a verification process in which you will be asked to provide us with two items of information known to you and to us.

Note: you may appoint an authorized agent to file requests to exercise your rights on your behalf. To this end, you must provide your authorized agent with written approval to do so. The authorized agent will have to present us with proof attesting that you authorized them to act on your behalf. Furthermore, we will require verification of your identity, as explained above.

Our Response to Your Requests

We will respond to your requests within 45 days (or within 90 days, where the law permits and we determine it necessary considering the complexity and number of the requests you have filed). If we take longer than 45 days, we will inform you of the extension within the initial forty-five-day response period, together with the reason for the extension.

Please note that any changes to your personal data that is controlled by your organization (including its deletion) will be subject to your organization's review and approval.

We may deny your request in the following cases:

   If we believe in good faith, based on reasons which are documented in writing, that your request is fraudulent or an abuse of your rights under applicable law.

   If we conclude that the request is irrelevant, based on all the circumstances at issue (e.g., if you requested to correct your personal information, and we find that it is likely to be accurate).

   If it is contrary to federal or state law.

   Due to a discrepancy in the required documentation.

   If the fulfillment of your request turns out to be impossible or involves disproportionate effort.

We will provide you with a detailed explanation including sufficient facts to enable you to meaningfully understand why we cannot fulfill your request.

You may appeal our decision to deny your request by submitting a written appeal to us at legal@clearmash.com.

 

 

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January 2026
 

Introduction

Welcome to the ClearMash Platform (the "Platform"). The Platform is a web-based, AI-driven knowledge-management platform that turns static company knowledge bases into actionable guidance, providing workflows, visual step-by-step instructions and intelligent alerts to shorten resolution times, boost compliance, and improve customer satisfaction. The Platform is owned and operated by ClearMash Solutions Ltd. ("ClearMash" or "we", "us", "our"). Use of the Platform is subject to our general Terms of Use.

We are committed to complying with applicable data protection laws. This Privacy Policy (“Policy”) explains how we collect and use your information when you access and use the Platform.

The Platform is not intended for users under the age of 18. We do not knowingly collect information from children under the age of 18 or knowingly allow minors under the age of 18 to use the Platform.

This Policy may be amended from time to time. We will post any change to this Policy on our Platform a reasonable time in advance of the effective date of the change, and we will also make efforts to proactively notify you of the changes if we have your email address.

 

Contact Us

If you have any questions, comments or concerns regarding this Policy or our processing of your personal information, please contact us through our online contact form or email us at legal@clearmash.com.

 

What We Collect and Why

Scenario

Purposes

Categories of information processed

Creating your Platform user account

Allowing you to use the Platform and its features, customizing the Platform to your preferences

We create your profile on the Platform per your organization's request. In this process, we collect and process your name, username, mobile phone number and email address. Your organization may also provide us with information about your department and role.

You may also decide to provide us your profile picture, and any preferences in relation to your use of the Platform (e.g., interface language, favorite pages, system notifications, etc.).

Your activity on the Platform

Providing you with the functionalities of the Platform; customizing the Platform to your preferences; improving and enhancing the Platform

The results of the knowledge tests you take; the contents of any ideas and/or suggestions in relation to the content available on the Platform that you submit through the Platform; the contents of the messages you share with other users in your organization through the Platform; the contents of your conversations with our AI features.

Please use discretion when deciding which information to share through the Platform. YOU ARE SOLELY LIABLE FOR PROTECTING THIRD PARTIES’ AND YOUR OWN PRIVACY, AND FOR OBTAINING THE PRIOR CONSENT OF INDIVIDUALS WHOSE PERSONAL INFORMATION YOU INCLUDE IN ANY MESSAGES OR INFORMATION YOU SHARE THROUGH THE PLATFORM. WE WILL NOT BEAR LIABILITY FOR ANY DAMAGES THAT YOU OR OTHERS MIGHT INCUR AS A RESULT OF THE INCLUSION OF PERSONAL INFORMATION IN THE TEXT YOU SUBMIT.

Please note that when you use our AI features, the information you receive is generated by AI models and not by humans. The AI features are intended for general informational and assistance purposes only and should not be relied upon as a substitute for professional advice, judgment, or decision-making.

Providing us with Testimonials

The operation of our business

You may provide us with your written, recorded or videotaped review or feedback about the Platform ("Testimonial").

Please use discretion when deciding which information to share in your Testimonial.

Contacting us through our online contact form

Responding to your inquiries; maintaining our customer relations with you; the operation of our business

Your username, email address, and the subject and content of your inquiry.

Use of cookies and analytics on the Platform

Operating the Platform; customizing the Platform to your preferences and needs; the operation of our business

Your organizational affiliation; information concerning your use of the Platform, e.g., IP address from which you accessed the Platform, time and date of access, type of device and browser used, language used, links clicked via a mouse or a touch screen, and actions taken while using the Platform.

You do not have a legal obligation to provide the above Information; however, if you choose to not share this information with us, we may not be able to manage your user account on the Platform, allow you to use various Platform functions, consider your ideas and suggestions, or respond to your questions and inquiries.

 

Methods and Sources for Collecting Your Personal Information

We collect the personal information from several sources:

   From your organization, for the purpose of creating your user account and for the ongoing operation of our Platform.

   Directly from you when you use the Platform (e.g., when you chat with our AI chatbot), provide us with Testimonials, or when you contact us.

   Through the device you use to access our Platform.

 

Sharing Your Personal Information

We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.

Scenario

Purposes

Examples of third parties involved

We will share your information with our service providers who assist us with the internal operations of the Platform. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes

Operating the Platform and managing our business

An updated list of our service providers may be found here

We will share your information with your organization

Maintaining our business relationship with your organization

Your organization

We will share your organizational chat messages and any ideas or suggestions you submit in relation to the Platform's content, with other users of the Platform within your organization

Providing you with the functionalities of the Platform; operating our Platform

Other users of the Platform within your organization

We will share your Testimonial (or parts of it) on our website and through our marketing materials

The operation of our business

Users of our website, prospective customers and investors

If you abused your rights to use the Platform or violate any applicable law while engaging with us

Responding to, handling, and mitigating suspected violations of law in connection with our business

Competent authorities, legal counsels, and advisors

If a judicial, governmental, or regulatory authority requires us to disclose your information

Complying with a binding request from a competent authority

Competent authorities

If the operation of the Platform or our business is organized within a different framework, or through another legal structure or entity

Enabling a structural change in the operation of the Platform and our business.

The target entity of the merger or acquisition, legal counsels, and advisors.

The third parties with whom we share information as described above may be located outside your jurisdiction, and subject to the privacy protection laws of these jurisdictions. If we transfer your personal information to other jurisdictions, we will do so in accordance with applicable law.

Cookies

We use cookies on the Platform in accordance with our cookies policy.

Data Retention and Security

We retain your information for as long as you are an active user of the Platform, and thereafter as needed for record-keeping purposes.

We will retain your information for as long as you are an active user of the Platform (or as otherwise requested by your organization), and for 30 days thereafter. Following that period, we will retain a backup copy of your personal information for two years, unless your personal information is required for a longer period to comply with our legal obligations, resolve disputes, establish and defend legal claims, and enforce our agreements.

We implement measures to secure your information

We implement measures to reduce the risks of damage, loss of information, and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, there is no guarantee that it will be immune from information security risks.
 

International data transfers

We may transfer, store, and process your personal data in countries other than your own, such as Israel.

The countries to which we transfer your personal data may provide a level of data protection that does not meet the level of protection provided by your country. In such cases, we take the appropriate safeguards required by applicable law to ensure that your personal data remains protected, including the implementation of standard contractual clauses or any other lawful transfer mechanisms recognized by applicable data protection legislation.

Your Rights

ClearMash Solutions Ltd. is the controller of the databases containing your personal information in relation to Testimonials and reviews and cookies. Our address is HaNofar 2, Suite 1003, Raanana, Israel.

Your organization is the controller of any other personal information processed when you use our Platform, as described herein

As a user of our Platform, you have the following rights in relation to your personal information:

   Right to review your information. You have the right to review, either by yourself or through an authorized representative or a guardian, any information we have stored about you in our databases.

   Right to request to rectify your information. If, upon reviewing your information, you find it to be incorrect, incomplete, or outdated, you have the right to ask us to rectify or delete it. We will inform you within 30 days whether we can comply with your request.

   Right to have your personal information deleted, under certain circumstances, such as when the information is no longer necessary for the purposes for which it was collected.

Please note that any changes to your personal data that is controlled by your organization (including its deletion) will be subject to your organization's review and approval.

Additional Information for Individuals in EEA And UK
 

Data Controller. The controller of your personal data we process when creating your user account on the Platform, through your activity on the Platform and when handling your inquiries, is your organization.

The controller of your personal data we process through your activity on the Platform, when you provide us with Testimonials and the data collected through cookies, is ClearMash Solutions Ltd. Our address is HaNofar 2, Suite 1003, Raanana, Israel.

International data transfers. To facilitate processing your information through the Platform (including by our service providers), we will transfer your information to and within countries outside the EU or the UK, such as Israel. We do so under an adequacy decision or under the terms of a data transfer agreement which contains standard data protection contractual clauses with adequate safeguards determined by the EU Commission and the UK Information Commissioner’s Office.

Legal basis for processing your personal data. We process your personal data under our role as data controller based on the following legal bases:

Purpose or Scenario

Legal Basis

Your activity on the Platform

Our legitimate interest in improving and enhancing the Platform.

Providing us with Testimonials

Our legitimate interest in the proper operation of our business.

Use of strictly necessary cookies on the Platform

Our legitimate interest in the proper operation of the Platform.

Use of optional cookies on the Platform

Your consent.

Analytics

Our legitimate interest in the proper operation of the Platform and our business.

Sharing your Testimonial on our website and through our marketing materials

Our legitimate interest in the proper operation of our business.

Responding to, handling, and mitigating suspected violations of law in connection with our business

Our legitimate interest in defending and enforcing against violations and breaches that are harmful to our business.

Complying with a binding request from a competent authority

Our legitimate interest in complying with mandatory legal requirements imposed on us.

Enabling a structural change in the operation of the Platform and our business

Our legitimate interest in our business continuity.

The legal bases for processing your personal data under our role as data processor are determined by your organization.

Data subject rights. If you are in the EEA or the UK, you have the following rights:

   Right to Access and receive a copy of your personal information that we process.

   Right to Rectify inaccurate personal information we have concerning you and to have incomplete personal information completed.

   Right to Data Portability, that is, to receive the personal information that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another person or entity. Where technically feasible, you have the right to have your personal information transmitted directly from us to the person or entity you designate.

   Right to withdraw your consent to processing your personal information, easily and at any time, if the basis for our processing is your consent. We may continue to process personal information with respect to which your consent is not necessary. Withdrawing your consent will not affect the lawfulness of the processing we carried out based on your consent before such withdrawal.

   Right to Object to our processing of your personal information based on our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or if we need to process such personal information for the establishment, exercise, or defense of legal claims.

   Right to Restrict us from processing your personal information (except for storing it): (a) if you contest the accuracy of the personal information (in which case the restriction applies only for a period enabling us to determine the accuracy of the personal information); (b) if the processing is unlawful and you prefer to restrict the processing of the personal information rather than requiring the deletion of such data by us; (c) if we no longer need the personal information for the purposes outlined in this Policy, but you require the personal information to establish, exercise or defend legal claims; or (d) if you object to our processing based on our legitimate interest (in which case the restriction applies only for the period enabling us to determine whether our legitimate grounds for processing override yours).

   Right to be Forgotten, under certain circumstances, such as when you object to our processing of your personal information based on our legitimate interest and there are no overriding legitimate grounds for the processing. However, notwithstanding such a request, we may still process your personal information if it is necessary to comply with our legal obligations, or for the establishment, exercise, or defense of legal claims. If you wish to exercise any of these rights, please contact us through the channels listed in this Policy.

We do not implement automated decision-making mechanisms in the Platform.

When you contact us with a request, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. If we are not able to provide you with the information that you have asked for, we will explain the reason.

Please note that any changes to your personal data that is controlled by your organization (including its deletion) will be subject to your organization's review and approval.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority in the Member State of your residence, place of work, or place of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

If you are in the UK, you can lodge a complaint to the Information Commissioner’s Office (ICO) pursuant to the instructions provided here.
 

Additional Information for Individuals in the United States

ClearMash Solutions Ltd. is providing the following additional information to its clients residing in the United States, pursuant to applicable state privacy laws in the U.S.

We do not sell your information to any third party, or share it for cross-context behavioral advertising. Furthermore, we do not collect, use or share sensitive information.

We keep the personal information specified below as long as necessary to operate the Platform. Following that period, we shall ensure that the information is not accessed, other than in extraordinary events such as legal disputes.

Categories of personal information we collect and process and their sources

Below are the categories of personal information we have collected and processed over the past 12 months, and the source of that information.

Categories of personal information

Details of the personal information that was collected

Sources of information

Identifiers

Name, account name, mobile phone number and email address; IP address

1.   From your organization.

2.   Directly from you.

3.   Through the device you use to access our Platform.

Professional or employment-related information

The organization you work for; your organizational affiliation; the results of the knowledge tests you take

Other information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Your inquiries and questions; your content ideas and suggestions; the contents of the messages you share with other users in your organization; the contents of your conversations with our AI chatbot; your preferences in relation to your use of the Platform

Visual or audio information

Your profile picture (if you chose to provide it); your Testimonial

Internet or other electronic network activity information

Data collected by cookies; Your activity on the Platform

 

Business purposes for the collection of personal information

Categories of personal information (per the table above)

Business purposes

Identifiers

Professional or employment-related information

Other information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Visual information

Internet or other electronic network activity information

1.   Providing services through the Platform.

2.   Debugging to identify and repair errors that impair existing intended functionality.

3.   Detecting and preventing security incidents.

4.   Undertaking activities to verify or maintain the quality or safety of the Platform and to improve, upgrade, or enhance the Platform.

Disclosures to third parties

Below are the categories of personal information we shared with third parties over the past 12 months and the categories of third-party entities we share them with.

Categories of personal information (per the table above)

Categories of entities we give the information to, and why

Identifiers

Professional or employment-related information

Other information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Visual information

Internet or other electronic network activity information

   Our service providers, who will use it only as necessary to assist us in the internal operations of our business and the Platform, and not for their own promotional purposes.

   Your organization.

   Other users of the Platform within your organization.

   Competent authorities, legal counsels, and advisors, if you abused your rights to use the Platform or violated any applicable law in the course of doing business with us.

   Judicial, governmental, or regulatory authority if they require us to disclose your information.

   Target entity of a merger or acquisition, legal counsels, and advisors If the operation of the Platform or our business is organized within a different framework, or through another legal structure or entity.

Your rights

The Right to Know. You have the right to know whether we are processing your personal information. If we are, you have the right to know the following information, which we will provide to you after we receive your request and verify your identity:

   The categories of personal information we collected about you.

   The categories of sources from which the personal information was collected.

   The purposes for which we collect personal information.

   The categories of third parties with whom we share personal information.

   The specific pieces of personal information we collected about you.

The Right to Obtain a Copy of Your Personal Information. If your data is available in a digital format, you have the right to obtain a copy of the personal information we hold about you in a portable and readable format (to the extent this is technically feasible).

The Right to Delete Your Personal Information. In some cases, state privacy laws provide for the right to request the deletion of your personal information.

The Right to Correct Inaccurate Personal Information. Once we receive a request from you to correct your data and verify your identity, we will examine the veracity of the corrected information you provided, consider your request to correct, and inform you of our decision.

To establish the veracity of the personal information as per your request, we will consider all circumstances pertaining to the personal information for which correction is requested. We may also require you to provide documentation in support of your request to correct the personal information.

The Right to Opt-Out of Processing for Solely Automated Profiling. You have the right to opt-out of solely automated processing of your personal information to evaluate, analyze, or predict your personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, where that processing is done in furtherance of a decision that produces a legal or similarly significant effect on you.

The Right to Non-Discrimination as a Result of Exercising Your Rights. You have the right not to be discriminated against by us for exercising the rights granted to you under applicable law. If you exercise your rights, we cannot:

   deny you services.

   charge different prices or fees for services, including through discounts, benefits, or fines.

   provide you with a different level or quality of services.

   propose that you receive different prices or tariffs for services.

Please note that we may charge a different fee or provide a different level or quality of services if the difference is reasonably related to the value we gain from your personal information.

Filing Requests

Should you wish to exercise your rights under applicable laws as specified above, please contact us by email at legal@clearmash.com.

To verify your identity, we will ask you to provide additional information through a verification process in which you will be asked to provide us with two items of information known to you and to us.

Note: you may appoint an authorized agent to file requests to exercise your rights on your behalf. To this end, you must provide your authorized agent with written approval to do so. The authorized agent will have to present us with proof attesting that you authorized them to act on your behalf. Furthermore, we will require verification of your identity, as explained above.

Our Response to Your Requests

We will respond to your requests within 45 days (or within 90 days, where the law permits and we determine it necessary considering the complexity and number of the requests you have filed). If we take longer than 45 days, we will inform you of the extension within the initial forty-five-day response period, together with the reason for the extension.

Please note that any changes to your personal data that is controlled by your organization (including its deletion) will be subject to your organization's review and approval.

We may deny your request in the following cases:

   If we believe in good faith, based on reasons which are documented in writing, that your request is fraudulent or an abuse of your rights under applicable law.

   If we conclude that the request is irrelevant, based on all the circumstances at issue (e.g., if you requested to correct your personal information, and we find that it is likely to be accurate).

   If it is contrary to federal or state law.

   Due to a discrepancy in the required documentation.

   If the fulfillment of your request turns out to be impossible or involves disproportionate effort.

We will provide you with a detailed explanation including sufficient facts to enable you to meaningfully understand why we cannot fulfill your request.

You may appeal our decision to deny your request by submitting a written appeal to us at legal@clearmash.com.

 

 

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