INCENTIVES SOLUTIONS LTD SERVICES PRIVACY POLICY.

This policy covers the privacy practices that Incentives Solutions Ltd and its subsidiaries and affiliates (“Incentives” or “We”) employ when providing online services and related applications accessible via Incentives Web site www.incentives-solutions.com (“Web Site”) pursuant to Incentives’ Master Online Subscription Agreement (the “Services”). By accessing and using our Web Site you are accepting the practices described in this Privacy Policy and are also agreeing to comply with our Terms of use. Before submitting your personal information to our Web Site, please read this Privacy Policy Carefully. This Privacy Policy is designated to assist you in understanding how Incentives collect, use and disclose personal information that we obtain through your use of our Web Site.

1. Information Collected

We collect individually identifiable information (“Personal Information”) from individuals who visit the Website (“Web Site Visitors”) and individuals who register to use the Services (“Customers”). Some information will be automatically collected using Cookies and similar technologies, but we ask your consent when required. Before using and sharing Personal Information through our Web Site, you should understand the different options you have and their meaning: when expressing an interest in obtaining additional information about the Services or registering to use the Services, Incentives requires you to provide the Company with personal contact information, such as your full name, company or organization name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services, Incentives may require you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of users that will be using the Services purchased by you (“Billing Information”). We may also ask you to provide, or otherwise allow you to share, additional information, which you may choose to share in your registration for or use of the Services (“Additional Information”). Required Contact Information, Billing Information, and Additional Information about Customers are referred to collectively as “Customer Information”. If We provide you with the Services, Incentives may also collect information through the use of commonly- used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser, your Internet Protocol (“IP”) address, HTTP header information, and the actions you take on the Web Site (such as the Web pages viewed and the links clicked).

2. Use of Information Collected

Incentives use Customer Information collected about you for registration (including registration for free trial), to manage your account, to perform the services requested by you, to communicate with you, to send product updates, send you push notifications when using our app, or to resolve disputes or troubleshoot problems. Incentives may also use Customer Information for marketing and advertising purposes and for legal reasons. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding Incentives, its affiliates, and its business partners, such as information about promotions, events or special offers that may be of interest to you. Incentives use Billing Information solely to check your financial qualifications and collect payment for the Services. Incentives use Web Site Navigational Information to operate and improve the Web Site. The Company may also use Web Site Navigational Information alone or in combination with Customer Information to provide personalized information about the Company and the Services. For additional information about the use of Web Site Navigational Information, please review Section 3 of this Policy. Incentives may use both Customer Information and Web Site Navigational Information and share it with third parties when it is necessary to comply with legal obligation: in response to subpoenas, court orders or other legal process, to establish or exercise our legal rights or as required by law; when we believe it is necessary to investigate, prevent or take action regarding illegal or suspected illegal activities, to enforce the  Web Site’s policies, our Terms of Use, or to protect the Company’s rights and intellectual property or the rights of others using the  Web Site or the Services or in connection with a corporate transaction such as investment, merger, consolidation, or asset sale. The data that is being collected from candidates that apply for a job opportunity via the web site is: name, Phone number, Email, Job title, Personal notes, CV file.

3. Cookies, Analytics/ Log Files

Incentives uses commonly used information-gathering tools, such as cookies and Web beacons, to collect information from your computer or mobile device as you navigate the Web Site, interact with e-mails sent by the Company on its own behalf, or use the Services (“Web Site Navigational Information”). This section describes the types of Web Site Navigational Information used on the Web Site and in connection with the Services, and how this information may be used.

Cookies

When visiting Incentives Web Site or using the Services, we use session “cookies” – a piece of information stored on your computer – to allow the Web Site or Services to uniquely identify your browser while you are logged in and to enable Incentives to process your online transactions. Session cookies also help us confirm your identity and are required to use the Service. We use persistent cookies that only We can read and use, to identify a user as an Incentives’ customer and make it easier for you to log in to the Services. Users who disable their web browsers’ ability to accept cookies will be able to browse our Web Site but will not be able to access or take advantage of the Service.

Analytics/Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base. We do not link this automatically collected data to personal information.

4. Information Sharing

Except as described in this policy, Incentives will not give, sell, rent or loan any Customer Information to any third party. Incentives may share Customer Information with: (i) Incentives’ contracted service providers, such as payment processors, business analytics, customer service, marketing, so that these service providers can provide services on our behalf; (ii) with Incentives’ service providers to ensure the quality of information provided; (iii) with other members and affiliates of Incentives to work with them, or with other companies or business partners to jointly offer products or services. Incentives may use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on Incentives’ behalf. We may also disclose Customer Information to respond to subpoenas, Court orders, or legal process, or to establish or exercise our legal rights and defend against legal claims.

5. Your European Privacy Rights Under GDPR

If you reside or otherwise find yourself in the territory of Europe, we are committed to facilitate the exercise of your rights granted by the EU General Data Protection Regulation. Otherwise, you can contact us at any time to discuss your privacy concerns.

Privacy rights under the EU General Data Protection Regulation include:

Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or concerns you can contact us any time.

Right of access, objection, restriction of processing, erasure, and portability. You also have the right to withdraw your consent at any time when we process your personal data based on your consent. To exercise these rights, please contact us at legal@incentives-solutions.com.

Right to opt-out to direct marketing. You have the right to opt-out at any time to receiving marketing materials from us by following the opt-out instructions in our commercial emails, by contacting us, at legal@incentives-solutions.com.

Please note that we reserve the right to send you other communications, including service announcements and administrative messages relating to your Incentives account (including the free trial period), without offering you the opportunity to opt out of receiving them.

Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you. We use cookies and similar technologies on our Web Site to personalize your experience on the Web Site and recommending software products and services that may be of interest to you. For additional information or to opt-out see Section 3 of this Policy.

Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal data infringes your privacy rights according to the General Data Protection Regulation, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:

• Right to rectification: if the Personal Information processed by Incentives is incorrect, incomplete, or not processed in compliance with applicable law or this Privacy Policy, you may have the right to have your Personal Information rectified.
• Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
• To exercise these rights, where applicable, please contact us by sending an email to: GDPR@incentives-solutions.com

6. International transfer of Personal Data

To facilitate our business practices, your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates in other countries where we operate, including countries outside the European Economic Area (EEA). We have implemented safeguards to ensure an adequate level of data protection where your Personal Data is transferred to countries outside the EEA, such as standard contractual clauses for the transfer of Personal Data as approved by the European Commission.

7. Data Retention

We retain the information we receive as described in this Privacy Policy above for reasonable duration, for example for as long as needed to provide our Services, comply with our legal obligations, resolve disputes, establish legal defenses, to conduct audits, pursue legitimate business purposes, and enforce our agreements. We will keep you profile information and content published until you decide to delete it or if it is not according to our Terms of Use.

8. Services Data

As part of using our Services, Customers may submit electronic data or information to the Services (“Services Data”) which may include Personal Information. Incentives generally has no direct relationship with the individuals to whom Services Data may pertain, which we process on the behalf of our customers. Any uses of Services Data by Incentives are done so pursuant to Incentives’ Master Online Subscription Agreement in place between Incentives and the relevant Customer (or his/her organization), which exclusively govern Incentives’ treatment of Services Data and supersede this Privacy Policy in case of conflict, or as required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Services Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, you should inquire with the Customer (or his/her organization) directly. If an authorized Customer requests that we remove or update the data in question and the Customer has no ability to do so via use of the Services, we will respond to their request within 30 business days.

9. Data Security

Incentives takes precautions, including administrative, technical, and physical measures to help safeguard Customer Information against loss, theft, and misuse as well as unauthorized access, disclosure, alteration, and destruction as set forth in Incentives’ Master Online Subscription Agreement. We shall maintain appropriate safeguards to ensure the confidentiality and security of the Customer Information submitted to us, and promptly inform Customer about any unauthorized or unintentional access to or disclosure of Customer Information. Customer and any of their users are solely responsible for protecting their passwords, limiting access to their computers, and signing out of the Services after their sessions.

10. Changes to Privacy Policy

Incentives reserves the right to change this Privacy Policy from time to time. Incentives will provide notification of the material changes to this Privacy Policy through Incentives’ Web site at least thirty (30) business days prior to the change taking effect.

11. Contacting Us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to Incentives at legal@incentives-solutions.com or by mailing Incentives Offices.