Privacy Policy

Last updated: April 15, 2019

This privacy policy (“Privacy Policy”) governshow we, Nous Machine Learning Ltd. (“Pecan”. “we”, “our” or “us”) use Personal Information (defined below) that we collect, receive and store pertaining to you (“User”, “you”) in connection with the following use cases:

  1. When you browse or visit our website, http://pecan.ai/ (“Website”)
  2.  When you make use of, or interact with, our Website:
  1. When you request a demo
  2. When you sign up for an account (log in as a Partner or as a Customer)
  3. When we process your job application
  4. When you subscribe to our emails list
  5. When you contact us (e.g. customer support, get in touch)
  1. When you make use of our platform Pecan
  1. When you create a new model of predictive analytics use case
  1. When you attend a marketing event and provide Personal Information
  2. When you exchange business cards with us
  3. When we acquire your Personal Information from third-party sources (such as lead-generation companies)
  4. When we use the Personal Information of our service providers and suppliers
  5. When we use the Personal Information of our customers
  6. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

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. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” 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. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. Period of storage of collected information
  3. How we protect and store your personal data
  4. How we share your personal data
  5. Additional information regarding transfers of personal data
  6. Your rights
  7. Use by children
  8. How can I delete my account?
  9. Links to and interaction with third party product
  10. Log files
  11. Cookies and other tracking technologies
  12. Analytic tools
  13. California privacy rights
  14. Our California do not track notice
  15. Deletion of content from California residents
  16. How to contact us

This Privacy Policy can be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below.  If there will be any significant changes made 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.

1.     What information we collect, why we collect it, and how it is used

Information we collect
Why is the Information collected and for what purposes?
Legal basis (GDPR only)
Third parties with whom we share your Information
Consequences of not providing the Information
When you browse or visit our website
Cookies, log files and analytic tools.

Read more in our cookie policy [add link]
We use cookies to understand how you use our site and to improve your experience. This includes personalizing content and advertising
Consent

Legitimate interest (e.g. essential cookies)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot collect and store the information

Cannot use or access some parts of the website
When you make use of, or interact with our Website
When you request a demo
·       Email address
·       Full name
·       Any other data you decide to provide/supply
·       To provide a demo
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. respond to a query sent by you)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot provide a demo
When you sign up for an account
·       Email address
·       Full name
·       Company name
·       Job title
·       Address
·       Payment methods and Billing information
·       Postal address
·       Any other data you decide to provide/supply
·       To create an account
·       To perform/execute the agreement
Processing is necessary for the performance of a contract to which the data subject is 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 create an account)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot create an   account

Cannot perform the agreement
When we process your job application
·       Full name
·       Email address
·       Phone number
·       CV
·       LinkedIn profile
·       Any other data you decide to provide/supply
·       To process your job application
·       To assess the candidate
·       To create an account
To send you marketing communications
Performance of a contract to which the data subject is 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 assess a candidate)
Consent
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot process your job application

Cannot assess your suitability as a candidate
Cannot send you marketing communications
When you subscribe to our emails list
·       Full name
·       Email address
·       To add you to our mailing list
·       To send you marketing communications
Consent

Legitimate interest (e.g. send you more information about Pecan)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot add you to our mailing list

Cannot send you marketing communications
When you contact us (e.g. customer support, get in touch)
·       Email address
·       Full name
·       Any other data you decide to provide/supply
·       To answer questions
·       To provide support
·      To send you marketing communications
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. respond to a query sent by you)
Consent
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot contact us and we cannot assist/help you
Cannot send you marketing communications
When you make use of our platform Pecan
·       IP Address
·       Device information
·       Cookies Read more in our cookie policy [add link]
·       To create a new model of [*]
Performance of a contract to which the data subject is 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 create a new model)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
We cannot create a new model
When you create a new model of predictive analytics
·      IP Address
·       Device information
·       To create a new model of predictive analytics
Performance of a contract to which the data subject is 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 create a new model)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
We cannot create a new model of predictive analytics
When you add a connection
·      Identifier
·      Host
·      Database name
·      Username
·      Password
·       Any other data you decide to provide/supply
·       To add a connection and/or another data source to the platform
Performance of a contract to which the data subject is 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 add a new connection to the platform)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot add a connection and/or another data source to the platform
When you attend a marketing event and provide Personal Information
·       Email address
·       Full name
‍·       Company name
·       Job title
·       Phone number
·       To establish a business connection

·       To send you marketing communications
The data subject has given consent to the processing of his or her personal data for one or more specific purposes

Legitimate interest (e.g. send you more information about Pecan)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot establish a business connection

Cannot send you marketing communications
·       To answer questions
·       To provide support
·      To send you marketing communications
When you exchange business cards with us
·       Email address
·       Full name
‍·       Company name
·       Job title
·       Phone number
·       To establish a business connection

·       To send you marketing communications
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. showing you certain products and features that you have shown an interest in).

Legitimate interest (certain B2B marketing communications)

Consent
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot establish a business connection

Cannot send you marketing communications
When we acquire your Personal Information from third-party sources (such as lead-generation companies)
·       Email address
·       Full name
‍·       Company name
·       Job title
·       To establish a business connection

·       To send you marketing communications

3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot establish a business connection

Cannot send you marketing communications
When we use the Personal Information of our service providers and suppliers  
·       Email address
·       Full name
·       Company name
·       Phone number
·       Any other data you decide to provide/supply
·       To contact our service providers

·       To perform/execute the agreement

·       To help us operate and improve the Services
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. perform the contract, send contract-related communications)
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot contact you

Cannot perform/execute the agreement

Cannot help us operate and improve the Services
When we use the Personal Information of our customers
·       Email address
·       Full name
·       Company name
·       Phone number
·       Job title
·       Any other data you decide to provide/supply
·       To provide our products and Services

·       To perform the customer agreement
·       To send you marketing communications
Processing is necessary for the performance of a contract to which our customer is a party.

Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).

Legitimate interest (e.g. send you contract-related communications)
Consent
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot provide the services

Cannot communicate with you

Cannot perform the agreement
Cannot send you marketing communications
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
·       Email address
·       Full name
·       Company name
·       Any other data you decide to provide/supply
·       To establish a business connection
·       To send you marketing communications
Depending on the context, legitimate interest (e.g. certain B2B marketing practices or replying your requests/questions), pre-contractual discussions (e.g. if you show interest in our products/services) or consent
Consent
3rd party platforms such as for the following purposes:
·       Marketing
·       CRM
·       Updates
·       Customer relationship
Cannot communicate with you
Cannot send you marketing communications

Finally, please note that some of the abovementioned Personal Data will be used for fraud detection and prevention, and for security purposes.

2.     Period of storage of collected information

Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request.  Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy [add link to the cookies policy]

3.     How we protect and store your information

a.        Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. 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.

b.       Retention of your Personal Information. In addition to the retention periods mentioned in Section 4 above, in some circumstances we may store your Personal Information 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 Information or dealings.

4.     How we share your personal information 

In addition to the recipients described in Section 4, we may share your information as follows:

o  To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

o  If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. 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 or assign Personal Information in connection with the foregoing events.

o  Where you have provided your consent to us sharing the Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional Services or functionality); and

o  Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

If you want to receive the list of recipients of your Personal Data, please make your request by contacting us to [*].

5.     Additional information regarding transfers of personal information  

Storage:

Access from Israel: Access from Israel (e.g. by our staff located in 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:

We ensure transfers within the Pecan group will be covered by an agreement entered into by members of the Pecan 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 help provide our products and 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; or

·       Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

6.     Your 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):

o   You have a right to access information held about you. Your right of access is 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 amend any Personal Data we hold that it is inaccurate or misleading.

o   You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;

o   The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;

o   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;

o   You have the right to object to profiling;

o   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. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority

o   The right to withdraw your consent. Please note that t 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.

  • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us at info@pecan.ai. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly 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 your identity and for security purposes, before disclosing the Personal Data requested to you. 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.

7.     Use by children

We do not offer our products or Services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

8.     How can I delete my account?

Should you ever decide to delete your Account, you may do so by emailing info@pecan.ai. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

10.   Log files

We make use of 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 may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

11.   Cookies and other tracking technologies

Our Site utilizes “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. For further information on cookies and how they are used in this site, please visit our Cookie Policy at https://www.pecan.ai/cookie-policy.

12.   Google analytics

The Site uses a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes Information specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your Information 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/.

13.   Access/accuracy

To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to info@pecan.ai. Your email should include adequate details of your request.

14.   California privacy rights

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@pecan.ai. Please note that we are only required to respond to one request per customer each year.

15.   Our California do not track notice

Platform:  We may collect personally identifiable information about an individual consumer’s online activities over time and across different sites and features of our platform, when a consumer uses the Services. If you choose to operate your web browser “do not track” signals or any other mechanism that provides consumers the ability to exercise choice regarding the collection of such information, we will abide by your request and stop collecting such information. We may allow third parties such as such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different sites and features of our platform and when a consumer uses the Services.

Website: We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services

16.   Deletion of content from California residents

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send us an email to info@pecan.ai. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

17.   Contact us

If you have any questions, concerns or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, we encourage you to first contact us at zohar@noos-ai.com.