Privacy Policy
Effective as of July 28, 2022
1. Purpose,
Scope, and Users
1.1. At LuGo Test
Technologies Ltd.(Tel Aviv-Yafo, 6967221, Yasha Hefets 14, Israel) we value your rights to privacy
and will do our best to make sure they are maintained. We make efforts to
comply with applicable laws and regulations related to personal data protection
in countries where we operate. This Policy sets forth the basic principles by
which we process your personal data, and indicates the responsibilities while
processing personal data.
1.2. We may be a data processor or
data controller. Regardless of our status, we will treat any personal data as
required by any applicable regulation, including but not limited to, Regulation
(EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on
the protection of natural persons with regard to the processing of personal
data and on the free movement of such data, and repealing Directive 95/46/EC
(General Data Protection Regulation) available at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ENG&toc=OJ:L:2016:119:TOC.
1.3. We understand that you are
aware of and care about your own personal privacy interests, and we take that
seriously. This Privacy Policy describes the policies and practices regarding
the collection and use of your personal data, and sets forth your privacy
rights. We recognize that privacy is an ongoing responsibility, and so we will
from time to time update this Privacy Policy as we undertake new personal data
practices or adopt new privacy and security rules.
2. Terms we use as legal guidelines of the processing
2.1. There are some legal bases for
the processing of your personal data and we count on them to process your
personal data. We use the main three bases to process your personal data:
consent, contract, and legitimate interest.
2.2. Consent - your clear agreement
to the processing of your personal data for a specific purpose.
2.3. Contract - the reason why the
processing is necessary based on a contract you have with us, or because we
have asked you to take specific steps before entering into that contract.
2.4. Legitimate Interests - the
reason why the processing your data is necessary which is based on the
legitimate interests or the legitimate interests of a third party, provided
those interests are not outweighed by your rights and interests.
2.5. Articles 6(1) and 9(2) of the
GDPR also indicate other legal grounds for the processing and when applicable
we will count on such grounds.
3. Consent rule
and interrelation with other legal grounds
3.1. If you have given consent to
the processing of your data you can freely withdraw such consent at any time by
emailing us or contacting via the contact form.
3.2. If you do withdraw your
consent, and if we do not have another legal basis for the processing of your
data, then we will stop the processing of the personal data.
3.3. If we have another legal basis
for the processing of your data, then we may continue to do so subject to your
legal interests and rights.
4. Our
responsibilities
4.1. If you are a registered user or
a visitor to the website who is a data subject, we act as the �data controller�
of personal data. This means we determine how and why your data are processed.
4.2. In some cases, we may not be
involved into the processing activity with your personal data. This may happen
when you use third parties to process your personal data.
5. Your
responsibilities
5.1. Read this Privacy Policy
carefully;
5.2. Make sure you understand all
your rights;
5.3. If you provide us with personal
data about other individuals, we will only employ that data for the special
reason for which it was provided to us. By sending the data, you confirm that
you have the right to dispose to process the data on your behalf in accordance
with this Privacy Policy;
5.4. Treat your personal data
confidential and secure;
5.5. In case if you submit third
party�s personal data, be sure that you have legal basis for the processing of
such data.
6. Collected data
6.1. We collect data when you
interact with its website, especially when:
6.1.1.you browse any page of the
website;
6.1.2.you use the website;
6.1.3.you purchase tests;
6.1.4.you pass tests;
6.1.5.you receive emails from us;
6.1.6.we check the identity of a
candidate and whether the candidate cheats;
6.1.7.we measure site traffic;
6.1.8.in cases which do not depend
on you but we have a legal basis to collect such data (see articles 6 and 9 of
the GDPR).
6.2. We collect the following types
of data:
6.2.1.contact details such as you�re
your first name, last name, email address, city, country, your company;
6.2.2.information necessary for the
tests such as profile pictures and screenshots;
6.2.3.data that identifies you such
as your IP address, login information, browser type and version, time zone
setting, browser plug-in types, geolocation information about where you might
be, operating system and version;
6.2.4.data on how you use the
website such as your URL clickstreams (the path you take through the website),
goods/services viewed, page response times, download errors, how long you stay
on webpages, what you do on those pages, how often, and other actions.
6.3. The recipients of the collected
data are the Director of the company, its employees, and other third party
service providers mentioned below.
7. Purposes and
Legal Basis for the processing
7.1. We process the data for:
7.1.1.Providing services and
verification of a candidate:
7.1.1.1. Details: we need to provide
services accessible via the website.
7.1.1.2. Legal basis: Contract.
7.1.2.Keeping the website running:
7.1.2.1. Details: managing your
requests, login and authentication, remembering your settings, processing
payments, hosting and back-end infrastructure.
7.1.2.2. Legal basis: legitimate Interests.
7.1.3.Preventing frauds, cheating,
illegal activity or any violation of the Terms or Privacy Policy:
7.1.3.1. Details: we may disable
access to the website in some cases of illegal activities or we need to check
whether the candidate cheats.
7.1.3.2. Legal basis: Contract,
legitimate Interests.
7.1.4.Improving the website
7.1.4.1. Details: testing features,
interacting with feedback platforms, managing landing pages, heat mapping the
website, traffic optimization and data analysis and research, including
profiling and the use of machine learning and other techniques over your data
and in some cases using third parties to do this.
7.1.4.2. Legal basis: Contract;
legitimate Interests.
7.1.5.Customer support
7.1.5.1. Details: notifying you of
any changes to the service, solving issues, any bug fixing.
7.1.5.2. Legal basis: Contract;
Legitimate Interests.
8. Data subject�s
rights
8.1. You may choose not to provide
us with personal data. If you choose to do so, you can continue to visit the
website and browse its pages, but we will not be able to process transactions
without personal data.
8.2. You may turn off cookies in
your browser via settings. You can block cookies on your browser refusing
cookies. You may delete cookies. If you turn off cookies, you can continue to
use the website and browse its pages, but the website and certain services will
not work properly.
8.3. You may ask us to refrain from
using your data for marketing (when applicable). You can opt out from marketing
by emailing us or contacting via the contact form.
8.4. You can exercise the following
rights by sending us an email or contacting via the contact form.
8.4.1.You have the right to access
information about you, especially:
8.4.1.1. the categories of data;
8.4.1.2. the purposes of data
processing;
8.4.1.3. third parties to whom the
data disclosed;
8.4.1.4. how long the data will be retained
and the criteria used to determine that period;
8.4.1.5. other rights regarding the
use of your data.
8.4.2.You have the right to make us
correct any inaccurate personal data about you.
8.4.3.You can object to using your
personal data for profiling you or making automated decisions about you. We may
use your data to determine whether we should let you know information that
might be relevant to you (for example, tailoring emails to you based on your
behaviour).
8.4.4.You have the right to the data
portability of your data to another service or website. We will give you a copy
of your data in readable format so that you can provide it to another service.
If you ask us and it is technically possible, we will directly transfer the
data to the other service for you.
8.4.5.You have the right to be
�forgotten�. You may ask erasing any personal data about you, if it is no
longer necessary for us to store the data for purposes of your use of the
website.
8.4.6.You have the right to lodge a
complaint regarding the use of your data by us. You can address any complaint
to your national regulator (see the list at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).
8.5. In the context of the right to
access information we shall provide you with the information within one month
of your request unless there is a justified requirement to provide such
information faster.
9. Security
9.1. We have security and
organizational measures and procedures to secure the data collected and stored.
9.2. Connections to the website are
encrypted using 256-bit SSL with integrity assured by the SHA2 RSA algorithm.
9.3. We use servers that comply with
strict international data security standards, including ISO 27001.
9.4. You acknowledge that no data
transmission is guaranteed to be 100% secure and there may be risks.
9.5. You are responsible of your
login information and password. You shall keep them confidential.
9.6. In case if your privacy has
been breached, please contact us immediately.
10. Location of
the processing of personal data and third party service providers
10.1. The personal data collected by
us is processed in Israel.
10.2. All payments are processed by
PayPal (see their Privacy Policy: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full?locale.x=en_GB).
10.3. Our website is hosted on
Google Cloud (Privacy Policy: https://policies.google.com/privacy).
11. Retention
period
11.1. We store personal data as long
as we need it and the retention practice depends on the type of data we
collect, regulatory burden, and how we use the personal data. The retention
period is based on criteria that include legally mandated retention periods,
pending or potential litigation, intellectual property or ownership rights,
contract requirements, operational directives or needs, and historical
archiving.
11.2. The images of your face,
screen, and workspace for the purposes of test integrity, person
identification, and anti-cheating measures are saved for up to 6 months and
then will be automatically deleted.
12. Cookie policy
12.1. We collect certain types of information
when you access or use the website, including cookies and similar tracking
technologies.
12.2. Cookies are small data files
that are placed on your computer or mobile device when you visit this website.
Cookies are used by the website in order to make the website work, or to work
more efficiently, as well as to provide reporting information.
12.3. You may always turn off some
of the cookies through your browser. If you turn off the cookies, this may
influence the functionality of the website.
12.4. The list of cookies we use is
listed in your browser.
13. Transfer of
your personal data
13.1. Personal data we collect from
you will be processed in Israel. Israel has sought and received a finding of
�adequacy� from the European Union under Article 45 of the GDPR. The State of
Israel is considered as providing an adequate level of protection for personal
data transferred from the European Union in relation to automated international
transfers of personal data from the European Union or, where they are not
automated, they are subject to further automated processing in the State of
Israel.
13.2. The competent supervisory
authority of the State of Israel for the application of the legal data
protection standards in the State of Israel is the �Israeli Law, Information
and Technology Authority (ILITA).