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PRIVACY NOTICE

Last updated: January 6, 2020 

This Privacy Notice is incorporated by reference into the company website.  

In this Privacy Notice, we refer to Essence Security International Ltd. (ESI),Essence SmartCare  (ESC) Ltd. and Essence Interactive Center (EIC), and their subsidiaries and associated companies as “we” or “us” or “our”, and we refer to you as “you” or “your”. 

We are the data controller for the data practices explained in this Privacy Notice. 

We comply with applicable data privacy and protection law. This means that when processing personal information for any purpose we must ensure it is: 

• Used lawfully, fairly and in a transparent manner
• Collected only for valid purposes that have been clearly explained and not used in any way that is incompatible with those purposes. 
• Relevant to the purposes we have told you about and limited only to those purposes. 
• Accurate and kept up-to-date. 
• Kept only as long as necessary for the purposes we have informed you about. 
• Kept securely

1.How We Collect Information, for What Purposes and Our Legal Basis for It 

This Privacy Notice is to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive when you do any of the following (“Relevant Services”):  

• Visit the Essence website at www.essence-grp.com (the “Site”) 
• Fill out a contact form for the purposes of technical or other support or to inquire regarding business opportunities 
• Willingly provide your personal information for the purposes of a current or potential business engagement  

Our legal basis for processing your data is our legitimate interest: it is necessary to collect and retain this information for the purposes of managing our business relationships, or pursuing a potential business relationship with you.  When you ask for technical support, our additional legal basis for processing your data is providing you the support you requested (‘performance of a service contract’).  

We use your data in order to provide the Relevant Services. Although you freely provide the information at your discretion, the information that we collect from you is required for us to provide you with the Relevant Services. 

1.1 The Personal Information we collect 

In the course of using the Relevant Services, we ask you to provide us with certain personal information (“Personal Information”). 

Personal Information includes, your name, contact details and professional details. 

We also process statistical analytics information about your use of the Relevant Services, such as general behavior patterns, IP address (and the general location corresponding to the address), time and date of access, type of browser used, language use, links clicked and the web pages you accessed.  

We do not knowingly collect personal information from children under the age of 18.  

1.2 Third Parties Receiving Information and International Data Flows 

Some of our services rely on third parties with whom we share some user information for the purpose of providing and maintaining these services to our users.   

These third parties include service providers that are authorized to use your personal information only as necessary to provide these services to us and our users, and not for their own promotional purposes. A list of these service providers is available at this link

We do not rent or sell your information to any third party. 

Any transfer of data outside your region to any third party service provider is done only to countries with adequate data protection, as defined by relevant regulations. 

Our services may be accessed internationally by us for the purpose of day to day use or service maintenance. 

We reserve the right to disclose any information obtained by us if required by law or by any governmental authority; in case of emergency; or to a successor entity in connection with a merger, acquisition, bankruptcy or sale of all or substantially all of our assets. 

1.3 Retention Period 

We will retain your personal information for as long as you use the Relevant Service, and for a period afterward, as dictated by a reasonable backup policy and any relevant regulations. 

1.4 Security 

We are concerned with safeguarding your information. We employ a variety of organizational and technical security measures designed to protect your information from unauthorized access and disclosure.  

Your information is protected, in compliance with ISO 27001 standards, using state of the art technical security measures, such as: 

• Encryption and authentication mechanisms 
• Regular threat and vulnerability assessment 
• Physical site security  

We also take various organizational measures to ensure data security, such as: 

• Lawful data processing reviews 
• Privacy impact assessments 

We cannot guarantee that your personal information or private communications will always remain private and secure. We are obliged to notify you of any security breach resulting in high risk of private data exposure.  

1.5 Cookie Policy 

Like many websites and applications, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer or mobile device for record-keeping purposes. You can instruct your browser or device, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Relevant Services. We may present links in a format that enables us to keep track of whether these links have been followed. 

2. Contacting Us 

If you have any concerns or questions about this Privacy Notice or would like to lodge a complaint, please contact our data protection officer or our EU representative at +972 (0)73 2447777, DPO@essence-grp.com

3.   Information for California consumers under the California Consumer Privacy Act (CCPA)

This is the information we have collected in the past 12 months about consumers using our Relevant Services

Categories of personal InformationSpecific Types of Personal Information CollectedSource of Information
IdentifiersName, contact details The user themselves
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual The content of your message to us The user themselves
Internet or other electronic network activity information Your usage patterns of the Relevant Services, IP address (and the general location corresponding to the address), time and date of access, type of browser used, language use, links clicked and the web pages you accessed The user´s devices
Proffesional InformationProffesional detailsThe user themselves

The following are the business or commercial purposes for which we use each category of personal information. Details about the information we collect for each category are provided in the table above.

Categories of personal Information Business or commercials purposes pursuant to CCPASpecifics purposes
Identifiers Providing customer service, processing or fulfilling orders and transactions, verifying customer information To provide our products and services
To verify your identity To communicate with you
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual
Professional Information Auditing relating to a current transaction with the customersTo improve our products and services and prevent fraud.

To receive feedback from you and inquire about any features you would like to see in future products and to promote new products or services .

Analyze our user database to review preferences and trends for our own internal statistical and analytical purposes.
Internet or other electronic network activity information Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality of the service and to improve, upgrade or enhance the service
Debugging to identify and repair errors

Please note that we do not sell your data and we have not done so in the preceding 12 months.

YOUR RIGHTS AS A CALIFORNIA RESIDENT UNDER THE CCPA

Disclosure of Personal Information We Collect About You You have the right to know:

·   The categories of personal information we have collected about you;
·    The categories of sources from which the personal information is collected;
·    Our business or commercial purpose for collecting personal information;
·    The categories of third parties with whom we share personal information, if any;
·    The specifics pieces of personal information we have collected about you;
Right to deletion Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
·   Delete your personal information from our records; and
·   Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
·   Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
·   Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
·   Debug to identify and repair errors that impair existing intended functionality;
·    Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
·    Comply with the California Electronic Communications Privacy Act;
·     Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
·    Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
·   Comply with an existing legal obligation; or
·   Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection against discriminationYou have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
·  Deny goods or services to you;
·  Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
·   Provide a different level or quality of goods or services to you; or
·    Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Designate an authorized agent to submit CCPA requests on your behalf

You may designate an authorized agent to make a request under the CCPA on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.
 

If you would like to exercise any of your CCPA rights as described above, you should either:

o   Complete a data subject request form on our website at https://www.essence-grp.com/contact/

o   Email us at DPO@essence-grp.com  

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require.

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