Effective Date: October 6, 2023
1 Purpose, scope, and users
Wiliot Ltd. (“Wiliot“, “Company”, “we“, “our” or “us“) develops and provides battery free Bluetooth chip technology (the “Product”), to increase the secured and continuous connection between people and products across the world.
We also operate and provide the website available at www.wiliot.com (the "Site") the web dashboard available at the Wiliot Software Development Kit (the “SDK”; and collectively - the “Services”), which allow our customers (“Customers”) to access and operate the Product.
We respect the privacy of our Sites visitors ("Visitors"), our Customers, and individuals who have installed the SDK on their device ("End Users"), and are strongly committed to making our practices regarding their personal data more transparent and fair.
Users of this document are all employees Wiliot.
You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best experience whenu sing our Services.
2 Reference documents
• ISO/IEC 27001 standard, clauses A.18.1.4
• ISO/IEC 27018:2014
• ISMS Manual
• Information Classification Policy
3 Company Policy
3.1 Data Collection
We collect the following categories of data (which, to the extent it relates to an identified or
Identifiable individual, will be deemed as “Personal Data“):
1. Data automatically collected or generated: When you visit, interact with or use our Services, we may collect or generate certain technical data about you. We do so either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).
Such data consists of connectivity, technical and aggregated usage data, such as IP addresses, device advertising ID, non-identifying data regarding a device (such as type, screen resolution), operating system, browser version, locale and language settings used, activities and actions on the Services, GPS location, date and time stamp, the cookies and pixels installed on a device, and the activity (clicks and other interactions) of Visitors, Customers and End Users in connection with our Services.
We mainly use this data to optimize our Product and the overall performance of our Services; and to gain a better understanding on how our Visitors, Customers and End Users typically use and interact with our Services and on how we could improve their user experience.
2. Data received from you: You may provide us with Personal Data such as your first and last name, address, email, phone number and account login details (such as usernames and hashed passwords) (collectively, “Account Data“), as well as any other data you choose to provide when you use our Services, create a user account or contact us.
3. Data received from our Customers: Customers may also provide us with data concerning their colleagues or employees, in order to allow them access to our Services. Such data usually refers to such individuals’ names/nicknames and work e-mails; however additional data may be provided at the Customer’s discretion.
4. Data received from third parties: we may receive your Personal Data from other sources. For example, if you participate in an event, conference or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or services provides, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.
3.2 Data Uses
We use Personal Data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing and advertising services, customer service and support operations, and protecting and securing our End Users, Customers, ourselves and our Services.
Specifically, we use Personal Data for the following purposes:
1. To facilitate, operate, and provide our Services;
2. To authenticate the data transmitted between the Product and the Services, and to allow our customers access to our Services;
3. To provide our Visitors, Customers and End Users with assistance and support;
4. To further develop, customize and improve the Product, the Services and the overall user experience, based on common or personal preferences, experiences and difficulties;
5. To contact our Visitors, Customers and End Users with general or personalized service-related messages (such as password-retrieval or billing) and promotional messages (such as newsletters, webinars, new features, etc.); and to facilitate, sponsor and offer certain events and promotions;
6. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
7. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
8. To comply with any applicable laws and regulations.
3.3 Data Location & Retention
Data Location: Your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers (defined below) in the United States of America, the EU and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.
Wiliot is headquartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
Data Retention: We keep Personal Data of Customers and Visitors for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.
We retain End Users’ Personal Data as instructed by our Customers, or as long as we consider necessary for the purposes described herein.
We will also retain Customers, Visitors and End Users Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. As required by laws applicable to log-keeping, records and bookkeeping, nd in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.
Please note that except as required by applicable law, we will not be obligated to retain your personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at firstname.lastname@example.org.
3.4 Data Sharing
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. Hosting services, data analytics services, marketing and
Advertising services, data and cyber security services, payment processing services, e-mail
Distribution and monitoring services, text messaging services, session recording, and our business, legal and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
Sharing Personal Data with our Customers: We may share the personal Data of End Users with their respective Customer. Please note that Wiliot is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of our Customer, that itself acts as the “Data Controller” of such data (as further described in Section 8 below).
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Wiliot, any of our Visitors, Customers or End Users, or of any members of the general public.
For the avoidance of doubt, we may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
3.5 Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.
While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and 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.
If you wish to prevent the use of your mobile device's advertising ID, you may change your device settings to reset such advertising ID (typically, this is available under the "Privacy" or "Ads" section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the "Settings" or "Help" section in your browser menu).
Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. We may also send you notifications, messages and other updates. You will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may send you notifications about new features, events and special opportunities or any other information we think our Customers will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites or products.
If you do not wish to receive such promotional communications, you may notify Wiliot at any time by sending an email to email@example.com, changing your communication preferences in your account, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
3.7 Data Security
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural, and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
3.8 Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, who determines the purposes and means of processing; and the “Data Processor”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
If Wiliot processes any End User Personal Data on behalf of a Customer, such Customer shall be deemed the “Data Controller” of its End Users’ data, and Wiliot will process such data on this customer’s behalf, as its “Data Processor”.
This means that in such cases, we will process such End Users’ data on behalf of our Customer and in accordance with its reasonable instructions, subject to our Terms of Service and other commercial agreements. The Customer will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
3.9 Data Subject Rights
If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR), to request access to, and rectification or erasure of your Personal Data held with Wiliot, or to restrict or object to such Personal Data’s processing, or to port such Personal Data – please contact us by email at firstname.lastname@example.org.
Please note that once you contact us by e-mail, we may require additional information and Documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. As proof of the identity of the person submitting the request), in accordance with Section 3 above.
If you would like to make any requests or queries regarding Personal Data we process on a Customer’s behalf, please contact such Customer directly. For example, if you are an End User who wishes to access, correct, or delete data processed by Wiliot on behalf of a Customer, please direct your request to the relevant Customer (who is the “Data Controller” of such data).
3.10 Children’s Privacy
Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at email@example.com.
3.11 Additional Notices
Legal officer has been designated as Wiliot’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Legal officer may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an mail to firstname.lastname@example.org. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
3.12 Validity and document management
The owner of this document is CISO, who must check and, if necessary, update the document at least once a year. When evaluating the effectiveness and adequacy of this document, the following criteria need to
• number of incidents related to data privacy in a manner specified in this document