Firmbase Ltd. (the “Company”, “we”) respects the privacy of its Site and Platform users (“User(s)” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you access and use our Site at devly.ai and its subdomains (the "Site") and/or our Platform (as such term is defined in the Platform’s respective Terms of Service), and all related services (the “Services”).

Please read the following carefully to understand Company’s views and practices regarding your personal information and how Company will treat it.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Platform's terms of use available at: https://www.devly.ai/terms, into which this Privacy Policy is incorporated by reference.

1.     Your consent (important, please read carefully!)

This Privacy Policy (“Privacy Policy”) details how your Personal Information collected via the Site and/or the Services and/or the Platform is used and processed by Company.

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR THE SERVICES AND/OR THE PLATFORM AND/OR SERVICES, OR OTHERWISE PROVIDING US WITH YOUR PERSONAL INFORMATION, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTIONS WHERE SUCH CONSENT IS REQUIRED) TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY AND COMPANY'S PRACTICES DESCRIBED HEREIN, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.

PLEASE NOTE: IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ENTER TO, CONNECT TO, ACCESS OR USE THE SITE AND/OR THE SERVICES AND/OR THE PLATFORM, OR OTHERWISE PROVIDE US WITH YOUR PERSONAL INFORMATION, IN ANY MANNER. FOR THE AVOIDANCE OF DOUBT, IF YOU ARE LOCATED IN A JURISDICTION WHERE THE COLLECTION AND PROCESSING OF PERSONAL INFORMATION IS DEPENDENT ON YOUR CONSENT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US. IF YOU FAIL TO PROVIDE SUCH CONSENT, YOU MAY NOT ACCESS OR USE THE SITE AND/OR THE PLATFORM, AND WE WILL NOT BE ABLE TO PROVIDE YOU WITH ANY SERVICES VIA THE SITE AND/OR THE PLATFORM OR CONTACT YOU.

2.     Who we are

In this Privacy Policy, references to Company, or to "we", "our" or "us" are to Firmbase Ltd. (company no. 516374956), which is a registered company in the State of Israel, having its principal office at 146 Derech Menachem Begin, Tel Aviv, Israel. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at: hello@devly.ai.  

3.     Which information may we collect about Users?

We collect from Users of our Site and/or Platform, and from Users who contacts us, two types of data and information:

3.1.   Non-personal Information. The first type is non-identifiable and anonymous information (“Non-Personal Information”). Non-Personal Information, which is being gathered, consists of:

·       Technical and Behavioral Information. You may access and browse the Site and/or use the Platform without disclosing personal information, although, like most websites and platforms, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site/Platform, the activities of the User on the Site/Platform and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers to obtain detailed analytics on the device and the User's behavior on the Site and Platform. Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain tracking technologies, such as cookies, as further detailed below.

3.2.   Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:

3.2.1.  Personal Information which is provided voluntarily:

●    Communications with Company: Personal Information you provide us as part of any communications with us, by any means, including by contacting us via the Site or email or through our social network pages (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences).

●    Contact Details: when using our Contact Us form available via the Site, we may collect certain information, such as your full name and email address. You may provide via the contact form your telephone number and any text you wish to insert into the “leave us a message” box. Additional information may be requested via the contact form in the future.

●    Mailing List: you may voluntarily join our mailing list by providing us with your email address via our Site.

●    Book a Demo: you may request a demo of our services by providing us with your full name, business email address and company website link. You may provide via the contact form any text you wish to insert into the “message” box. We may request additional information to complete your application.

●    Client and Account Information: When you subscribe to our Platform, we register you as a new client and collect certain information necessary to establish and maintain your Account, including contact person details (name, role, company affiliation, and contact information), account credentials and login information (usernames, email addresses, and passwords), administrative and billing contact information, and company or organization details. We may also collect additional information when you request technical support, access training materials, participate in Platform updates, or communicate with us regarding your use of the Platform. If you provide information on behalf of third parties—such as details of contact persons within your organization, permitted users of the Platform, or other individuals associated with your Account—you represent and warrant that you have obtained all necessary consents from such individuals to provide their information to us, that you are authorized to share such information in accordance with this Privacy Policy.

●    Payments: When subscribing to the Platform, you will have the option to use certain Online Payment Processors which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information). We will not store such information on our servers. We only keep token information such Online Payment Processors provide us with (and where applicable, the last four digits of your credit card number), and such information is strictly secured.

3.2.2.  Personal Information collected via technology:

●    IP address: Users of the Site and/or Platform may automatically provide their IP address (or MAC Address, as applicable) mainly for enhancing the User’s experience and for geo-location, security and targeted advertising purposes, as further detailed below.

●    Geolocation data: during your use of the Site and/or Platform, we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of Internet Protocol (IP) addresses and other similar information to determine your location for providing our services, advertising and for analytics and security purposes.

●    Technical and Behavioral Information: to the extent that the Technical and Behavioral Information will be linked to or associated with a specific individual then such information will be considered as Personal Information.

3.3.   Please note:

●    We may cross-reference your Personal Information with other Personal Information we may have about you. Any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.

●    We use third-party tracking services and usage logs, to track and analyze data from Users of the Site and for purposes of security and fraud prevention. We may also use cookies to gather information regarding your use of the Site and the information for which you searched and accessed (for more information please see below).

4.              How do we collect information about our Users?

There are two main methods we use to collect information:

4.1.   We collect information through your entry, connection, access and/or use of the Site and/or the Services and/or the Platform. In other words, when you access or use the Site, we are aware of your usage and may gather, collect and record the information relating to such usage. For example, when you use the Site or Platform, we gather your Technical and Behavioral Information.

4.2.   We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide through email correspondence or via the "Contact Us" form on our Site.

5.              What are the purposes of the collection and processing of information?

5.1.   Non-personal Information is processed in order to:  

●    Enhance the User’s experience on the Site and/or the Services and/or the Platform;

●    Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others);

●    Statistical analysis of the Site; and

●    Keep the Site and/or the Services and/or the Platform safe and secured against fraudulent and criminal activity.

5.2.   Personal Information is processed in order to:

●    Enable the operation and constant improvement of the Site and/or the Services and/or the Platform;

●    Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone, through web-browser notification or through the post. You have the right to opt-out of marketing messages at any time by following the instructions in such messages or by contacting us at: hello@devly.ai;

●    Formulating, personalizing, optimizing, customizing and enhancing the User's experience on the Site and/or the Platform;

●    Send push notifications to Users. Users of the Platform can deactivate push notification by changing their settings within our Platform or by using their web browser/device’s settings;

●    Administer your Account on the Platform and verify the User's identity when they sign into the Platform;

●    Be able to contact Users for the purpose of providing them with technical assistance and support;

●    Determine the User’s geo-location to safeguard the Site and/or the Platform;

●    Register your interest in our products and services;

●    Contact you by telephone and/or by email with further information relating to our products or services which you enquired about via the Site. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you;

●    Enable our third-party advertising service providers to present you with Company's advertisements on websites and platforms across the Internet and across devices. You may opt-out from such advertising activities by following the directions detailed below;

●    Conduct internal operations, such as: troubleshooting, data analysis, testing, research, and statistical analysis;

●    Keep the Site and/or the Services and/or the Platform safe and secured against fraudulent and criminal activity;

●    Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests; and

●    Maintain our data processing records and general administrative purposes.

6.              Sharing Personal Information with Third Parties

6.1.   The Company respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.

6.2.   In addition to using the information collected by us for the purposes described under Section 5 above, we may also share your information in the following cases:

●    Company Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of Company for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 5 above). Please note that all Company personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information. 

●    Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site and/or the Services and/or the Platform. Please note that we collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction.

●    In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy or any other agreement or terms of service between you and Company, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of Company, its Users or the general public; (e) when Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company (while such acquired company or investor may be located in countries outside of your jurisdiction); (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment;  or (g) pursuant to your explicit approval prior to the disclosure.

6.3.   For avoidance of doubt, Company may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site and/or the Services and/or the Platform.

7.              Your Rights

The Company hereby informs you that you have the right (subject to certain conditions) under applicable law to access Personal Information we collect and process about you, and in certain cases to request its amendment or deletion. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: hello@devly.ai and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.

8.              Location of Your Data

The Personal Information collected from you by Company, as detailed in this Privacy Policy, may be transferred to, and stored in, servers which may be located in countries outside of your jurisdiction and in countries that are not considered to offer an adequate level of protection under your local laws. It may also be processed by Company and its suppliers, service providers or partners' staff operating outside your country.

The Company is committed to protecting your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps may include, but not limited to, putting in place data transfer agreements and ensuring our third-party service providers comply with Company's data transfer protection measures.

BY SUBMITTING YOUR PERSONAL INFORMATION TO COMPANY, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

9.              Minors

The Site and/or the Services and/or the Platform are intended for Users over the age of eighteen (18). Therefore, Company does not intend and does not knowingly directly collect any Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Site and/or the Services and/or the Platform.

10.     Direct Marketing

You hereby agree that we may use your contact details you provided us with (including, without limitation, e-mail address and phone number) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future products and Services, through e-mails, SMS or regular mail. You may withdraw your consent by sending a written notice to Company's e-mail: hello@devly.ai or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.

11.           Third Party Service Providers

While using the Site and/or the Services and/or the Platform, we may be using third party service providers, who may collect, store and/or process the Personal Information detailed herein. Such third parties may be located in a country that does not have the same data protection laws as your jurisdiction. Company uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such third parties’ software or services may include without limitation the following categories of service providers:

·       Analytics services, including Google Analytics and Apollo.io;

·       Hosting and cloud service, including AWS;

·       Advertising partners, including Google, Microsoft and Meta;

Please read such third party service providers' terms of use and privacy policies to understand their privacy practices.

12.           Links to Third Party Websites

The Site and/or the Services and/or the Platform may provide certain links which permit Users to leave our Site and/or the Services and/or the Platform and enter non-Company sites or services. Most of such linked sites and services provide legal documents, including terms of use and Privacy Policy governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information about you is being collected.

13.           Security

13.1.   We take appropriate measures to maintain the security and integrity of our Site and/or the Services and/or the Platform, and prevent unauthorized access to it and to Personal Information or use thereof through generally accepted industry standard technologies and internal procedures.

13.2.   Your Personal Information is hosted on third party servers, which provide advanced strict security standards (both physical and logical).

13.3.   Some of the security measures that we employ include, without limitation: the application of highly secure design and implementation methods to our Services and/or Site and/or Platform, including state of the art encryption mechanisms and secure architecture design to all storage and transmission mechanisms used for the processing and transmission of your Personal Information, as well as access control and auditing systems (including firewall and identity management solutions), that restrict access to your Personal Information to authorized personnel only, based on their roles and their need-to-know requirements, needed to process your Personal Information on Company’s behalf.

13.4.   Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.

13.5.   Company will comply with applicable law in the event of any breach of security, confidentiality, or integrity of your Personal Information and will inform you of such breach as required by applicable law.

13.6.   TO THE EXTENT THAT COMPANY IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.   

14.           Data Retention

Company will retain the Personal Information for as long as we are confident that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

15.           Payments

We accept certain online payment methods, using our Online Payment Processors, which enable Users to send and receive payments securely online using a credit card or bank account. We may add or change the Online Payment Processors at our sole discretion. The Company is not affiliated with such Online Payment Processors (for more information see our TOU), as each is an independent contractor, and neither is the agent or employee of the other, and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Processors is at the User's discretion and sole liability and risk. It is the User's responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies, including but not limited to any age restrictions specified therein. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

16.Cookies and Tracking Technologies

When you access or use the Site and/or Platform, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, "Cookies") which may enable us, amongst others, to recognize your device from those of other Users of the Site and/or Platform, to improve the Site and/or Platform 's performance, to deliver a better and more personalized service according to our Users' individual interests and the device or browser used, to track Users' use of the Site and/or Platform, to gather information about the Users' approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern, to provide targeted and behavioral based advertising, and perform other analytics and to develop our Site and/or Platform. 

Cookies may locally store certain Technical and Behavioral information and other Personal Information on your device and we and/or our authorized third party service providers may access such information for the purposes detailed under this Privacy Policy. We and/or our authorized third party service providers may use both session Cookies (which expire once you close the web-browser) and persistent Cookies (which stay on the User’s device until he/she deletes them).

Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the Site may be limited.

For detailed instructions regarding the blocking of Cookies, please refer to your browser's 'help', 'tool' or 'edit' sections or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.

It is possible to opt-out of having your browsing activity within the Site and the Platform recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users' activities on the Site, including by use such services' persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.

17.           Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Site and/or the Services and/or the Platform and any information collected with respect thereto. Company reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Site and/or the Platform, or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Site and/or Platform or sent to you via e-mail, whichever is earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Site and/or the Services and/or the Platform on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

18.           Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, please send us an email to the following address: hello@devly.ai, and we will make an effort to reply within a reasonable timeframe.