Last Revised: April 7 2019
SAGARMATHA Ltd. (“SAGARMATHA” or “we”) respects the privacy of its Site’s users (“User” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our primary website at https://www.sag121.com (the “Site”). Please read the following carefully to understand SAGARMATHA’s views and practices regarding your personal information and how SAGARMATHA will treat it.
Table of Content
- Who we are
- Your acknowledgment of this policy
- Which information may we collect about Users?
- How do we collect information about our Users?
- What are the purposes of the collection and processing of information?
- Sharing Personal Information with Third Parties
- Your Rights
- Location of Your Data
- Third Party Service Providers and Third Party Software
- Links to Third Party Websites
- Cookies and Similar Technologies
- Data Retention
- Have any Questions?
1. Who we are
In this policy, references to SAGARMATHA, or to “we” or “us” are to SAGARMATHA Ltd., which is a registered company in the state of Israel (No. 512765645) at EuroPark Yakum, Israel. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at firstname.lastname@example.org.
2. Your acknowledgment of this policy
3. Which information may we collect about Users?
We collect from Users of our Site, two types of data and information:
3.1. Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).
You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc; and (ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers such as Mixpanel and Google Analytics to obtain detailed analytics on the device and the User’s behavior on the Site.
Please note that we or our third party service providers will collect such Technical and Behavioral Information by using certain technologies such as Cookies (as further detailed below under Section 12 “Cookies & Local Storage”).
3.2.Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:
3.2.1. Personal Information which is provided voluntary:
- Communications with SAGARMATHA:Personal Information you provide us as part of any communications with SAGARMATHA, by any means, including by approaching our customer services or during sales calls. We may record such calls for quality assurance purposes and in order to improve our services.
- Contact Details:when you enquire about SAGARMATHA’s services from the Site, we will ask you to provide us some or all of the following details: full name, e-mail address, phone number, company and country. A free text message may also be provided. You may also voluntarily join our mailing list by providing us with your email address.
- Job Applicants:information you provide us when applying for a position via the “Careers” page available on the Site, as further detailed under Section 3.2.3 below.
3.2.2. Personal Information collected via technology:
· Geolocation data and the identity of your company: while using the Site we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of IP addresses and other similar information to determine your location for the purpose of providing a localized version of our Site and for security purposes. Please note that we may also analyze your IP address, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse our Site, for the purpose of locating prospects and in order to analyze our Site’s traffic.
- Technical and Behavioral Information:to the extent that the Technical and Behavioral Information detailed above under Section 3.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
- Identifiers:such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or another unique identifiers.
3.2.3. Personal Information relating to job applicants:
You may use the “Careers” page available on our Site in order to apply for a position at SAGARMATHA and send us your CV, and in such case the following applies:
- The Personal Information collected as part of the application process, including any Personal Information included in your CV, may be accessed by our HR department and/or by SAGARMATHA managers, worldwide, solely for the purposes of evaluation and to enable us to contact you with respect to the recruitment process.
- Personal Information may be retained for future consideration by SAGARMATHA (e.g. future positions at SAGARMATHA) solely to the extent that we receive your permission.
- Please note that if you have successfully recruited to work for SAGARMATHA, any Personal Information collected as part of the application process may be retained by SAGARMATHA for the purposes of your employment.
- We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
4. How do we collect information about our Users?
There are two main methods we use to collect information:
4.1. We collect information through your entry, connection, access and/or use of the Site. In other words, when you access or use the Site we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.
4.2. We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide via the Contact Form on our Site. We will inform you prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.
5. What are the purposes of the collection and processing of information?
5.1. Non-personal Information is processed in order to:
- Enhance the User’s experience on the Site;
- Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and
- Keep the Site safe and secured and for prevention of fraud.
5.2. Personal Information is processed in order to:
- Enable the operation of the Site;
- Contact you by telephone and/or by email with further information relating to our products or services which you enquired about via the Site;
- Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone, through web-browser notification or through the post (having first obtained your consent and subject to your right to opt-out of marketing messages at any time by following the instructions in such message or by contacting us at: email@example.com.)
- Contact you for the purpose of processing your job application (having first obtained your consent and subject to your right to withdraw such consent at any time);
- Personalize your experience on the Site (e.g. geolocation data shall be used to provide you with a localized version of the Site (where available));
- Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
- Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
- Keep the Site safe and secured and for prevention of fraud and crime;
- Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site;
- Maintain our data processing records and general administrative purposes;
- Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
Note to our Users in the EU:
In order for SAGARMATHA to process your Personal Information, as detailed herein, such processing must be justified by a “basis” for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:
- the processing is necessary to comply with a legal obligation– we may process your Personal Information for disclosure of information to authorities; and
- the processing is in our legitimate commercial interests– subject to your interests and fundamental rights, under our legitimate interest in marketing our products and services via the Site and offering the public comfortable and safe access to our Site, we shall process all other Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site, assisting us to prevent crime and fraud, our internal operations, maintaining records and email tracking. We may also use the information contained in certain cookies and other such files or tags consists based on such ground for our legitimate interests in a safe and user-friendly presentation of our Site.
Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
6. Sharing Personal Information with Third Parties
6.2. In addition to using the information collected by us for the purposes described under Section 4 above, we may also share your information in the following cases:
- Local Distributors and Sales Representatives: When you provide us with your contact details via the Site or make certain requests for information about SAGARMATHA products or services, we may transfer your name and contact information to the local distributor, dealer, reseller or sales representative of SAGARMATHA products and services that is located close to your location, solely in order to enable us to respond to your request. We identify the nearest distributor, dealer or sales representative using the location that you provided us. Please note that we instruct our local distributors, dealers, resellers and sales representatives to maintain appropriate data security safeguards in place and they are contractually restricted from using your Personal Information for any purpose other than in order to offer you SAGARMATHA’s products and services, and/or in order to respond to any other specific request that SAGARMATHA has received from you. We note that such distributors, dealers, resellers and sales representatives may separately ask you to provide your name and contact information for other marketing activities. Any information that you may transfer to them directly will be used by them according to their privacy practices and SAGARMATHA will not be responsible for their use of such information.
- SAGARMATHA Personnel:Personal Information that we collect and process may be transferred to or accessed by personnel of SAGARMATHA for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 4 above). Please note that all SAGARMATHA personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
- Service Providers:we share Personal Information with vendors, commercial software providers, consultants and data processers who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party’s cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 10 below.
6.3. For avoidance of doubt, SAGARMATHA may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.
7. Your Rights
SAGARMATHA acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: firstname.lastname@example.org and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
- Right to access: you may have the right to request a review of your Personal Information held by SAGARMATHA.
- Right to erasure: under certain conditions, you may be entitled to require that SAGARMATHA will delete or “block” your Personal Information (e.g. if the continued processing of those data is not justified).
- Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity).
- Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
- The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
- 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: email@example.com
8. Location of Your Data
Note to our Users in the EU:
If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.
In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:
- Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;
- Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;
- Transferring your Personal Information to organizing that are Privacy Shield Scheme certified, as approved by the European Commission.
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
The Site is intended for Users over the age of sixteen (16). Therefore, SAGARMATHA does not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site.
10. Third Party Service Providers and Third Party Software
10.2. Note, that we collect, hold and/or manage your Personal Information through SAGARMATHA’s authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
10.3. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
10.4. Such third parties service providers include without limitation the following categories of service providers:
11. Links to Third Party Websites
12. Cookies and Similar Technologies
12.3. First and third party Cookies – First-party Cookies are Cookies that belong to us and that we place on your device. Third-party Cookies are Cookies that another party, which provides us a service, places on your device through your use of our Site. For example, to administer our Site and for research purposes, we have contracted third-party service providers to track and analyze statistical usage and volume information from our Site Users. Third-party Cookies may also be placed on your device by our business partners so that they can use them to advertise products and services to you elsewhere on the Internet.
12.4. Do we track whether users open our emails? Our emails may contain a single “web beacon pixel” which enables us to verify whether our emails (and any links or advertisements within the email) are opened. We may use this information to determine whether our emails are of interest to Users, to approach Users who do not open our emails and verify whether they wish to continue receiving them and to inform our advertisers in aggregate of the audience size for their advertisements. Please note that such “web beacon pixel” will be deleted once you delete the email from your email account. If you do not wish the “web beacon pixel” to be downloaded to your device at all, please set your email account settings to receive emails from us in plain text rather than HTML.
12.5. What sort of Cookies does our website use? Generally, our Cookies perform the following functions:
· Essential Cookies – those Cookies are essential to navigate around the Site and use its features. For example, they allow us to remember your Cookie preferences and to verify if something is not working properly, so we can fix it quickly.
· Analytical and Performance Cookies – those Cookies are used to analyze how our Users use our Site and to monitor the Site’s performance. For example, we might use performance Cookies to keep track of which pages are frequently visited and from what locations our Users come from. We might also use these Cookies to highlight Site services that we think will be of interest to you based on your usage of the Site. We generally use third party Cookies to perform these services, for example, Google Analytics.
· Functionality Cookies – those Cookies allow us to operate the Site in accordance with your preferences when browsing the Site.
For example, such Cookies save you the trouble of typing in a username every time you access the Site, and recall your customization preferences, such as your preferred text size, fonts, languages and other parts of the Site that are alterable.
12.6. Can a Site User block Cookies? Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a cookie is stored. However, if you block or erase Cookies, your experience of the Site may be limited. Please note that unless you block the acceptance of Cookies, the Site will utilize Cookies upon your use of the Site (all unless it is required by applicable law to provide a separate consent to use such Cookies, and in which case we will use such Cookies only after we receive your separate consent to such use and subject to your right to withdraw such consent at any time). For detailed instructions regarding the blocking of Cookies, please refer to your browser ‘help’, ‘tool’ or ‘edit’ section or see http://www.allaboutcookies.org/manage-cookies/. If you want to remove previously stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Site from placing further Cookies on your device unless and until you adjust you settings as described above.
Opting out of performance Cookies – It is possible to opt-out of having your browsing activity within the Site recorded by performance Cookies. Please note that we use Google Analytics and Mixpanel as our service providers in order to track Users’ activities on the Site, including by use such services’ persistent Cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.
Opting out of target advertising Cookies – Please note that if you want to opt out from receiving targeted advertising, this does not mean that you will receive less advertising when you use our Site, but rather that the advertising you see will not be as customized to your interests. You can visit the Internet Advertising Bureau’s consumer advice site at http://www.youronlinechoices.com/uk/your-ad-choices, which will provide you further information, a list of all Cookies that are currently set on your device and instruction on how to opt-out of each of them.
13.1. We take appropriate measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.
13.2. Your Personal Information is hosted on InterSpace servers, which provide advanced strict security standards (both physical and logical) and is subject to restriction of access to individuals who need access to it in order to process it on SAGARMATHA’s behalf.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
13.3. SAGARMATHA will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.
13.4. TO THE EXTENT THAT SAGARMATHA IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, SAGARMATHA SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.
14. Data Retention
SAGARMATHA will retain the Personal Information for as long as we are comfortable that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.
16. Have any Questions?