Privacy Policy

1.1. This privacy policy (“PP”) explains how Langware Inc., (together with its affiliated companies – “Langware”, or the “Company”) collects, stores, uses, processes, and shares, personal data of our customers, end users and/or their Personnel (as applicable) (for the purpose hereof, collectively, the “Users”) in connection with the Company’s services, as may be offered by the Company from time to time (the “Services”). For the purpose of this PP “Personal Data” shall mean any information that refers to, is related to, or is associated with an identified or identifiable individual, pursuant to applicable data protection laws, including the Israeli Privacy Protection Law, 1981, and where applicable the GDPR and CCPA (both are as defined below) (the “Law”). The PP is an integral part of the Company’s Terms of Use, or any other agreement executed between the Company and the Customer governing the use of the Services (“Terms and Conditions”, together with the PP, the “Terms”).

1.2. This PP does not apply to any Personal Data that Company is provided with, processes, and manages on behalf, or at the direction of the User, with respect to the Services, where User decides how and why Personal Data is processed (“User Data”). Such User Data is processed by the Company pursuant to our Data Processing Addendum (“DPA”), subject to and in accordance with the Law, in our position as the ‘Processor’ (as defined in the Law).

1.3. It shall hereby be clarified that User is not under any legal obligation to submit Personal Data to Company. However, in case User chooses not to submit Personal Data to Company, User may not be able to use the Services or any part thereof. By attempting to use or access, or by accessing and/or using the Services, User agrees to be bound by the Terms. If User does not agree with the Terms (or any part thereof), User must not access or use the Services. User’s acceptance of the Terms will be deemed as User’s consent to the processing of User’s Personal Data for all purposes detailed in this PP. To revoke such consent, (to the extent applicable) User may contact us at privacy@langware.ai.

1.4. All capitalized terms used but not defined herein shall have the meaning ascribed to them in the Terms or the Law.

3.1. Company and Company’s third-party service providers may use tracking mechanisms such as cookies on the Services so that Company may: (i) facilitate, analyze, personalize, improve and customize the User’s experience of the Services; and (ii) track User’s use of the Services.

3.2. A cookie is a small text file that is stored on User’s computer for record-keeping purposes which contains information about that User. Most browsers automatically accept cookies, but User may be able to modify its browser settings to decline cookies. Please note that if User declines or deletes these cookies, some parts of the Services may not work properly. User may find more information about cookies the Company (or its service providers) uses as well as options to opt-out of cookies or to change User’s cookie preferences at any time by using the ‘Cookies Setting’ tool available on the footer of the Services.

3.3. This PP does not apply any products, services, websites, links or any other content that are offered by third parties on the Services. User is advised to check the applicable third-party policies. Company has no control over such third parties’ privacy practices, or the technology used by such third parties. Each User is advised to thoroughly review such third parties’ privacy policies before making any use of such third party’s products and services. This PP does not cover the use of cookies by any third parties, and Company is not responsible for such third parties’ privacy policies and practices.

4.1. Company processes User’s (or its Personnel’s) Personal Data to operate, provide, maintain, and improve the Services, including for the following purposes:

• Creating and managing User’s account
• Contacting User and communicating with User with respect to the Company’s Services
• Recognizing and identifying User on the Services
• Evaluating User’s behavior (tracking) on the Service
• Improving marketing efforts and promoting Company’s Services
• Providing assistance, notification and support
• Fulfilling User requests and providing customer care
• Meeting contractual or legal obligations
• Protecting User’s security, e.g. preventing and detecting fraud
• Protecting the rights or property of the Company
• Complying with applicable laws and regulatory requirements, or as requested by government or regulatory authorities
• Internal purposes, e.g. trouble shooting, data analysis, administrative, testing and statistical purposes

4.2. The Company also uses pseudonymized (rendered non-personal), statistical or aggregated information, which may be based on User’s (or its Personnel’s) Personal Data provided and/or collected hereunder, for the purpose of providing the Services, including for testing, development, improvement, control and operation of the Service.

4.3. Except as provided herein, the Company does not use any Personal Data obtained hereunder, except as permitted under applicable law.

4.4. The Company may ask for User’s consent to use User’s Personal Data for a specific purpose which will be provided to User.

5.1. The Company retains or discloses, without notification, Personal Data that the Company collected and/or was provided with, in order to operate, support, maintain, provide and improve the Services, as well as in the following cases:

• The Company engages selected third-party companies and individuals as “Service Providers”, to perform services on the Company’s behalf or complementary to its own. These may include amongst others, providers of: hosting and server location services, data and cyber security services, infrastructure/software providers, professional advisors, and support and customer relation management systems. The Company’s Service Providers may have access to Personal Data, depending on each of their specific roles and purposes in the provision of the Services or other activities, and may only use Personal Data as determined in the Company’s agreements with them.
• As set forth under Section 3 above.
• For integrations with third-party services.
• If required to do so by law or regulations according to its understanding of such law or regulations (including, but not limited to, in cases of court orders or subpoenas or other legal process).
• To verify the information obtained by Company.
• To enforce or apply Company’s terms and other agreements, or protect the rights, property, or security of Company, User, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
• To prevent or investigate suspected fraud, or any activity that Company believes may be illegal or may expose the Company to legal liability.
• Events involving potential threats to the physical safety of any person or property, if the Company believes that the respective information in any way relates to that threat.
• If Company believes that User’s (or its Personnel’s) conduct on or in connection with the Services is inappropriate and inconsistent with generally accepted norms of behavior.
• Company may be required to disclose data to relevant national, state and local law enforcement authorities, who may further disclose the data.
• In the event that the Company, or any of its businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, data may be one of the assets sold or merged in connection with such transaction. Personal Data may also be disclosed in connection with a commercial transaction where Company or any of its businesses are seeking financing, investment, and support or funding.
• When Company shares data with third parties, as specified above, Company requires such recipients to agree to only use such Personal Data in accordance with this PP and Company’s contractual specifications and for no other purpose than those determined by Company in line with this PP. However, it is clarified that Company is not liable for such third parties’ use of the Personal Data.

The data that Company processes in relation to Users or User Personnel may be transferred to, and stored at a destination outside the European Economic Area (“EEA”), e.g., United States of America, Europe, Israel, that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who works for us or for one of our service providers: (i) in order to store it; (ii) where we are legally required to do so; (iii) in order to facilitate the operation of our businesses, where it is in our legitimate interests and we have concluded these are not overridden by User’s rights.

Where Personal Data is transferred by Company in relation to providing the services Company will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, which may include by entering into European Commission approved standard contractual clauses relevant to transfers of Personal Data and that it is treated securely and in accordance with this PP.

To the extent the California Consumer Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq. (“CCPA”), including any subordinate or implementing legislation, is applicable the following shall apply:

The Company will only process personal information on User’s behalf.

The Company will (i) not collect, retain, use, or disclose personal information for any purpose other than for the specific purposes set out in the PP, or any other agreement between Company and User; (ii) not sell Personal Information (as defined under the CCPA); and (iii) put in place appropriate technical and organizational measures to protect personal information against unauthorized or unlawful processing or accidental destruction, loss or damage.

Subject to the Israeli Privacy Protection Law, 1981 (“PPL”) and its implementing regulations, User and its Personnel, have the following rights with respect to User and Personnel Personal Data (as defined in the PPL) processed by the Company, and Company will act in accordance with the PPL, to comply with requests to exercise such rights:

• Right to Review: the right to review Personal Data about User and/or Personnel, processed by the Company.
• Right to Rectification: request the Company to correct any inaccurate or incomplete Personal Data processed by the Company.
• Right to Deletion: the right to request the deletion of Personal Data about User and/or Personnel in the context of direct marketing communications.
• To exercise any of these rights, User may contact the Company at privacy@langware.ai.

The Company may modify this PP from time to time. The Company will seek User’s prior consent to any material changes, in accordance with the Law.