The website op.today, the OP.sign app and the Pangolin messaging platform (the “Software”) are provided by Pangolin Labs Ltd., an Israeli company (“Pangolin“, “we” or “us“). Pangolin is committed to protecting your privacy and the security of your Personal Information. The following provisions set forth and explain how we collect, use, protect, and disclose your Personal Information, User Content and Usage Data (as such terms are defined herein) when you use the Software (“Privacy Policy”). Please read the following Privacy Policy carefully as it includes important information regarding the use of your Personal Information. Together with our End User Terms of Use, the Privacy Policy governs your use of the Software.

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By using the Software, you consent to the terms of this Privacy Policy and to the practices described herein. Please note that your Personal Information may be processed in countries where laws regarding processing of Personal Information may be less stringent than the laws in your country.

The Software is secured messaging service for professional purposes, which enables real time communication within organizations and between organizations, with co-workers, partners, clients, and other third parties. Users who register for the Software using the organizational email address allocated to them by their organization and/or place of employment (“Organization”) will become members of their Organization’s group on Pangolin. The Software is based on “chat rooms”, which are registered in an Organization’s name. Users may communicate both with (i) other users within their Organization in their Organization’s chat room(s), and (ii) users of other organizations (“External Users” and “External Organizations” respectively) within either their Organization’s chat room(s) (should they invite the External User to their Organization’s chat room) or the External Organization’s chat room(s) (if they are invited by an External User to such External User’s External Organization’s chat room). Please note that a chat room will be registered in the name of the Organization with which the User who initiated the chat room is associated; and this information will be displayed to all Users who participate in that chat room, regardless of the Organization they are associated with.

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Your Organization has certain rights with respect to your Data (as defined below) and is solely responsible towards you for the privacy of your Data. In addition to the foregoing, in the event that you communicate in an External Organization’s chat room, then, the chat room, and the data transferred therein and parts of your Data may be available to, monitored and managed by such External Organization and members of such External Organization. In such cases, Pangolin does not assume any direct or indirect liability or obligation towards you with respect to the maintenance or use of your Data, and any claim, complaint, request or demand that you may have with respect to your Data, should be made only vis-a-vis the relevant Organization. To the maximum extent permitted by applicable law, Pangolin will not respond to any claim, complaint, request or demand made by you. You hereby waive any claim that you may have against Pangolin, and any claim that the above deprive you of an adequate remedy. Without derogating from the aforementioned, Pangolin will not have any liability towards you under Pangolin’s agreement with the Organization or External Organization (as applicable) or as a result of Pangolin’s compliance or non-compliance with the instructions of the Organization or External Organization (as applicable).

When the Software is installed on the servers of an Organization or an External Organization (or its suppliers or affiliates), Pangolin may not have any access to Data (as defined below) and the Data shall be used, maintained, processed and controlled in accordance with the Organization or External Organization’s policies. This Privacy Policy describes Pangolin’s policy only with respect to Data which Pangolin receives.

For further details, please contact the Organization’s (or External Organization’s) Administrator.     

 

Data We Store

1. 1. Personal Information – Pangolin may store information that is unique to you, such as your name, address, profile picture, phone number, profile information, organizational and/or private e-mail address, title and other personally identifiable information (“Personal Information”). Pangolin receives such Personal Information from you both when you voluntarily provide such Personal Information to Pangolin and via your use of the Software. For example, Pangolin may receive your Personal Information when you register for the Software, upload a profile picture to your account, or contact Pangolin with inquiries or when such information is provided in messages by you or by other users.

   2. User Content – in some cases (mainly when the Software is used in the Software as a Service model) we receive and store your messages and associated content (including any data, information, files, documents and content you may upload, publish, display, transfer and receive when using the Software (the “User Content”).

   3. Usage Data – We also may receive or collect, from the computer, mobile phone or other device you use to access and use the Software, other types of data and information about you, such as technical information about your laptop, tablet, mobile device and system, software, your usage of the Software, location data, time zone, browser type, language preference, etc. (“Usage Data”)

   4. The Personal Information, User Content (if applicable), Usage Data and any other data or information we may receive from you are collectively referred to as “Data“.

   5. In addition, we may receive Data you voluntarily provide to, or collected by, the payment processor in connection with a payment you have made.

 

How Do We Use Your Data

1. 1. We generally use the Data we receive and collect in connection with the management, operation, maintenance, optimization, improvement and enhancement of our Software and our users’ experience.

   2. In addition, we may use the Data collected by us, as follows:

1. 1. 1. In order to provide you with the Software and to administer, operate and maintain your account and use of the Software;

      2. For the same purpose the Data was provided to us and in connection with the reason for which it was provided, including in order to provide you with access to or use of the Software or any functionality thereof;

      3. To respond to your emails, submissions, questions, comments, requests, and complaints and provide you with customer service and technical assistance and support;

      4. To send you confirmations, updates, security alerts, support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Software;

      5. To monitor and analyze usage and trends, and to personalize and improve the Software, and prevent fraud;

      6. To collect payments;

      7. To enforce an agreement or to protect our rights;

      8. To connect you to third parties and to allow you to share User Content with third parties;

      9. For the purpose of analysis, statistics and the like; and.

      10. According to the instructions of the Organization or External Organization, as applicable.

1. 1. You acknowledge and agree that we may use subcontractors worldwide to provide our Software.

 

Monitoring by Your Organization

As set forth above, your Organization may control your Pangolin account and shall be entitled to receive, monitor, process and analyze your account and any of your Data. Furthermore, in the event that you communicate in an External Organization’s chat room, then, the External Organization may control such chat room and shall be entitled to receive, monitor, process and analyze the chat room, and some of your Data. The Organization and External Organization may do so by appointing one or more individual users to oversee the use of the Software, and monitor the User Content uploaded, posted or transferred, by users who belong to such Organizations (an “Administrator”). Your Organization and the Administrator will have access to your Data and may be able, without limitation, to do any of the following:

• View statistics regarding your account;

• Change your account password;

• Suspend or terminate your account access;

• Access, view and retain Data stored as part of your account;

• Assume control over your account;

• Restrict your ability to delete or edit Data. 

In addition to the foregoing, an External Organization and its Administrators will have access to your Data which is available to them as part of your participation in External Organization’s chat room, and may be able, without limitation, to do any of the following:

• Suspend or terminate access to the chat room;

• Access, view and retain Data stored as part of the chat room;

• Assume control over the chat room;

• Restrict your ability to delete or edit Data available as part of the chat room. 

 

Sharing Data

Pangolin will not voluntarily share or disclose your Data, unless otherwise permitted according to the other provisions of this Privacy Policy or the following terms:

1. 1. 1. Pangolin may share your profile picture, username and other information with users of the Software who have permission to see such information, based on privacy preferences set in your account.

      2. Pangolin may share your Personal Information with certain social networking services, only if you allow such sharing through the Software;

      3. Pangolin may share your Data with third party companies and individuals that provide Pangolin with a variety of services, including payment processing and storage. These trusted third parties may have access to your Data, to the extent it is reasonably necessary for them in order to perform their tasks pertaining to their engagement with Pangolin;

      4. Pangolin may share your Data in order to facilitate the provision of software updates, product support and other services to you (if any);

      5. For the purpose of analysis and statistics, provided that such disclosure is done anonymously and is non-personally identifiable;

      6. Pangolin may share your Data with its employees, consultants, contractors, resellers, service providers and suppliers. Such disclosure is normally subject to the recipient’s undertaking of confidentiality obligations and the prevention of any independent right to use this Data by the recipients, except as required to help us provide the Software.

      7. Pangolin may share your Data with its subsidiaries and/or affiliates for purposes consistent with this Privacy Policy;

      8. Pangolin may also transfer your Data in connection with, or during the negotiation of, a merger, consolidation, change of control or other corporate reorganization in which Pangolin participates.

      9. If required to do so by law, or in the good-faith belief, that disclosing such Data is necessary to comply with any law or respond to any court order, search warrant or equivalent, or where in Pangolin’s reasonable belief an action is needed in order to protect the personal safety of any individual; and

      10. In case Pangolin believes, in good faith, that such disclosure is required under applicable law or is appropriate or necessary in order to enforce its General Terms and Conditions or End User Terms and Conditions, collect payments, take precautions against liabilities, investigate and defend itself against any third party claims or allegations, assist government enforcement agencies, protect the security or integrity of its application and servers and protect its rights and property.

 

General Privacy Provisions

1. 1. Pangolin processes and stores Data on its or its partners’ servers in many countries around the world, and by using our Software you acknowledge and agree that your Data may be processed and stored on any of our or our partners’ servers, at any location.

   2. Pangolin’s software is a messaging platform and therefore works better when more people use the Software and are available for communication. Pangolin encourages people to send invitations to others who are not registered on Pangolin. If you choose to provide us with email addresses, phone numbers or other data of third parties within or outside your Organization, we will use that information to enable the invitation of such users to Pangolin. For the avoidance of doubt, if you provide us with information of third parties, you hereby represent and warrant that such third parties have given their informed consent to processing and use of their personal information as set forth above. You agree to indemnify us and hold us harmless from and against all claims, losses, damages, liabilities, actions, causes of action, penalties, costs and expenses, including reasonable attorney and professional fees and costs, arising out of or in connection with any claim by any third party.

   3. In addition to the above, by using the Software, you allow Pangolin to periodically access your contact list and address book, in order to suggest contacts that you may want to add to your Pangolin account. If you choose to add them to your Pangolin contact list, Pangolin will send them an invitation by email or text message on your behalf, which may include your name, picture and other profile information.

   4. We may use cookies (a string of information that can be stored on your computer, if your web browser is set to permit storage of cookies) to help us learn about how you use the Software and to enhance your online experience.

   5. If you are a registered user of Pangolin and have supplied us with your email address, you may occasionally receive emails from us relating to your account, or with respect to updates on new features or other changes in the Software, or for customer service purposes, or otherwise as shall be required in order to enable your use of our Software. Pangolin may also contact you regarding third-party inquiries as described in the Terms of Use and this Privacy Policy.

   6. Pangolin may be required to provide you with support services, which may be provided through phone, email, online chat or otherwise by Pangolin. Phone conversations and online chat sessions may be recorded and/or monitored and we will use such data in the same way as we use your Data, as described in this Privacy Policy.

 

Security

We care about the security of our Software, and therefore use advanced technical and organizational measures designed to secure the Data which we store from accidental loss and from unauthorized access, use, alteration or disclosure. However, there is always risk involved in the electronic transmission and storage of Data and allowing access to electronic systems. As a result, Pangolin cannot fully ensure or warrant the absolute security and privacy of your Data, and you acknowledge and agree to these reservations.

 

Deactivation and Deletion of Your Personal Information

If you want to delete or remove your Personal Information stored with us, please contact your Organization (or the relevant External Organization, if such Personal Information is stored as part of an External Organization’s chat room). Subject to applicable law, Pangolin will respond to such requests only if submitted by an authorized representative of the Organization. Please note that some information may not be deleted from all databases and backup records. We may also retain certain Personal Information for customer service, legal and similar purposes. We reserve the right to keep all non-Personal Information and continue to use such non-Personal Information in accordance with this Privacy Policy after the termination of your account and deletion of all your Personal Information, as set forth above.

 

Children’s Privacy

We do not knowingly collect or solicit Personal Information from anyone under the age of 18 or knowingly allow such persons to register for the Software. If you are under 18, please do not use the Software. If you believe that we might have any Personal Information from or about a child under the age of 18, please contact us promptly at contact@op.today

 

Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes to this Privacy Policy are binding and effective when they are posted on this page (https://op.today/privacy).  To the extent that we have your e-mail address on record, we may use this to inform you of changes to this Privacy Policy.

 

Contacting Us

If you have any questions about this Privacy Policy, our information practices, or your dealings with us, you can contact us at contact@op.today.

 

Last Updated: March 8, 2020

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