Terms of Service 

These Terms of Service, along with any other terms and policies referenced herein, which are an integral part hereof, as amended from time to time, together with any applicable Order Form and the Privacy Policy (each, as defined below), constitute a legally binding agreement (this Agreement) between the Customer and Circles IT Innovation Ltd. (“Circles”) governing the Customer’s and its Authorized Users access to, and use of the Services (as defined below).  

By executing an Order Form that references to this Agreement or using the Service (either as Customer or as an Authorized User), you agree to the terms of this Agreement.  

  • Definitions

The following words and phrases shall have the following meanings when used in this Agreement:

  1. Additional Services” means such additional services as described in the Order Form (if any). 
  2. Applicable Law” means all law and regulations, including country laws, state and federal laws, directives, rules, regulations, executive orders and regulatory requirements (or any other form of secondary legislation) applicable to the relevant party.
  3. Authorized Users” means individuals who are authorized by Customer to use the Service on its behalf, subject to the terms of this Agreement. 
  4. Customer means the person or entity that enters into the applicable Order Form. 
  5. Customer Data” means Customer’s and Authorized Users’ data, information and content that is submitted, transmitted or displayed via the Services. 
  6. Confidential Information” means information, in whatever form disclosed, provided by or on behalf of one party (“Disclosing Party”) to the other party (“Receiving Party”), or to which the Receiving Party otherwise gains access, in the course of or incidental to the performance of this Agreement, and that should reasonably be understood by the Receiving Party because of legends or other markings, the circumstances of disclosure or the nature of the information itself, to be proprietary and confidential to the Disclosing Party or a third party. Without derogating from the generality of the above, the Software shall be Confidential Information of Circles. For the purposes of this Agreement, any Customer Data shall be Confidential Information of Customer. 
  7. Documentation” means the documentation describing or related to the Software and the Services and required to use them in accordance with this Agreement, including training and marketing materials. 
  8. Fees” means the fees payable for the Services set forth in the Order Form.
  9. Initial Term” as defined in the Order Form. 
  10. Intellectual Property Rights means all trade secrets, patents and patent applications, trademarks (whether registered or unregistered and including any goodwill acquired in such trade marks), service marks, trade names, business names, internet domain names, e-mail address names, copyrights (including rights in computer software and algorithms), moral rights, database rights, design rights, rights in know-how, rights in Confidential Information, rights in inventions (whether patentable or not) and all other intellectual property and proprietary rights (whether registered or unregistered), and, in each case, all other equivalent or similar rights which may subsist anywhere in the world; all derivative works thereof; and any current or future applications, renewals, extensions, restorations, provisionals, continuations, continuations-in-part, divisions, reexaminations and reissues thereof.
  11. Order Form” means any order form regarding the provision of the Services, signed between Circles and the Customer.
  12. Privacy Policy” means Circles’ privacy policy (located at: router-test-circles.eco/privacy) as amended from time to time, which is hereby incorporated by reference. 
  13. Services” means access to the Software on a Software-as-a-Service (“SaaS”) basis and the Additional Services (if any). 
  14. Software” means Circles’ platform for innovation processes management. 
  15. Term means the Initial Term and (if applicable) any renewal thereof. 
  • The Services
      1. During the Term and subject to the terms of this Agreement (including Customer’s compliance with its payment obligations thereunder):
        1. Circles shall provide the Services to the Customer according to this Agreement.
        2. Circles may also provide Customer with reasonable technical support services in connection with the Software. 
      2. Customer may not access or use, or attempt to access or use, the Software and/or the Services and/or the Documentation, in any manner which harms or may harm Circles or any third party, the operation of the Software, or may result in a violation of any law, including, without limitation, by: 
        1. attempting to decipher, decompile, disassemble, reverse-engineer or attempting to discover the source code of the Software; 
        2. altering, removing, obscuring, or changing the location, content, or appearance of any disclaimers, notices of copyright, trademark, service mark, or other proprietary rights, or other notices included in the Software and/or the Services; 
        3. using any device, software, or routine to interfere or attempt to interfere with the proper working of the Services or any activity conducted on the Services or attempt to probe, scan, test the vulnerability of, or breach the security of any system or network; or 
        4. modifying, disassembling, reverse engineering or attempting to modify, or by creating or trying to create, any derivative work of the Software.
      3. Customer shall not (a) make any Service available to anyone other than Customer or any Authorized User, or use any Service for the benefit of anyone other than Customer, unless expressly stated otherwise in an Order Form, (b) sell, resell, license, sublicense, distribute, rent or lease any Service,  (c) modify, copy, or create derivative works of a Service or any part, feature, function or user interface thereof. 
      4. The number of Authorized Users to whom the Customer may allow access to the Services may not exceed the maximum number of Authorized Users specified in the Order Form. 
      5. Customer will (a) be responsible for Authorized Users’ compliance with this Agreement and for the accuracy, quality and legality of any Customer Data, and (b) use commercially reasonable efforts to prevent unauthorized access to or use of Services, and notify Circles promptly of any such unauthorized access or use.
      6. Customer shall not allow any person to use and/or access the Services unless (i) such person is an Authorized User; (ii) such person has agreed to this Agreement, the Privacy Policy and any other applicable terms governing the Authorized Users’ use of the Service. 
  • Feedback 
      1. Customer shall provide Circles, from time to time, with user feedback, ideas or suggestions and recommendations with respect to the Software and/or Services (“Feedback”). 
      2. Customer hereby grants Circles a royalty-free, fully paid-up, non-exclusive, worldwide, perpetual, irrevocable, sub-licensable and assignable license to use, edit, aggregate, reproduce, distribute, create derivative works of, publicly display, publicly perform, and otherwise fully exploit such Feedback, for any use and purpose whatsoever, subject to the terms of this Agreement and of the Privacy Policy.  
  • Representations and Warranties

Customer hereby represents, warrants and undertakes (a) that it is duly organized and validly existing under the laws of its jurisdiction of formation and has the full power and authority to enter into this Agreement; (b) that it is not bound by any agreements, obligations or restrictions that would interfere with its obligations under this Agreement; (c) that it possesses and shall maintain at all applicable times all rights, licenses, permissions and consents required to perform its obligations under this Agreement including all licenses required under Applicable Law to conduct its business and to use the Services; (d) not to engage, in connection with this Agreement in any illegal, unfair, or deceptive business practices or unethical conduct whatsoever, and otherwise abide with all Applicable Law and not to use the Service to transmit (a) any information or material that is libelous, defamatory, obscene, racist or otherwise offensive, or (b) any information or material that infringes the intellectual property, moral, publicity or privacy rights of any third party.

  • Fees
      1. In consideration for the provision of the Services during the Term, Customer shall pay Circles the Fees, in accordance with the payment terms specified in the Order Form. 
      2. Circles reserves the right to change the Fees or applicable charges and to institute new charges and Fees at the end of the Initial Term or then-current renewal term, with advance notice to the Customer as set forth in the Order Form. 
      3. All Fees are exclusive of VAT. Customer shall be responsible for all taxes associated with the Service other than taxes based on Circles net income.
      4. Unpaid amounts payable hereunder shall bear interest at a rate of 1.5% per month on any outstanding balance, or the maximum permitted by law, whichever is lower.  
  • Audit 

Circles shall have the right, upon reasonable notice to Customer and during the normal business hours, to audit the use of the Services and to inspect Customer’s records related thereto.

  • Term

This Agreement shall be effective as of the execution date thereof and for a period of 12 months thereafter and thereafter shall be automatically extended for additional periods of 12 months each, unless either party requests termination at least 30 days prior to the end of the then-current term, all unless otherwise provided in the Order Form. 

  • Termination
      1. Circles shall be entitled to terminate this Agreement immediately in the event of material breach of this Agreement by the Customer and/or any Authorized User, which is not cured (to the extent curable) within 14 days from the day a notice of such breach was given to the breaching party.
      2. Upon termination or expiration of this Agreement, (i) all rights granted to Customer hereunder shall automatically expire and Customer shall discontinue all use and access to the Service; (ii) Circles will make all Customer Data available to Customer for electronic retrieval for a period of 30 days, but thereafter Circles may, but is not obligated to, delete stored Customer Data. 
      3. Sections ‎‎4, ‎9, ‎10, ‎11, ‎12, ‎15, ‎16 and ‎17 hereof shall survive termination of this Agreement. 
  • Confidentiality 
      1. The Receiving Party shall use the Confidential Information solely as necessary to fulfill the Receiving Party’s obligations or exercise its rights under this Agreement, and not for any other purpose, without the prior written consent of the Disclosing Party (the “Permitted Use”).
      2. The Receiving Party shall not disclose the Confidential Information to any third party, other than to its employees, agents and contractors whose knowledge of the Confidential Information is required in connection with the Permitted Use and who are subject to legal obligations of confidentiality consistent with this Section ‎10, and shall take all reasonable precautions (and not less than those employed by the Receiving Party with respect to its own confidential information) to ensure the Confidential Information is kept in confidence and is not disclosed or used in violation hereof. 
      3. Regardless of the above, the Receiving Party shall not be required to treat the following information as Confidential Information: (i) information which is in the public domain, or later becomes part of the public domain through no wrongful act on behalf of the Receiving Party; (ii) information furnished to the Receiving Party by a third party not restricted from freely disseminating the information; (iii) information already known to the Receiving Party prior to the receipt thereof from the Disclosing Party; and (iv) information that is developed by the Receiving Party independently and without reference to any Confidential Information received from the Disclosing Party.
      4. Confidential Information may be disclosed as required by Applicable Law or by order of a court provided that, to the extent possible, the Receiving Party will provide Disclosing Party with prompt prior notice of such obligation in order to permit Disclosing Party an opportunity to take legal action to prevent or limit the scope of such disclosure.
      5. Within 30 days of the termination or the Term according to the Order Form or upon Disclosing Party’s request, whichever shall first occur, Receiving Party shall return or destroy all Confidential Information disclosed hereunder and all copies thereof, at the choice of the Disclosing Party to be delivered in writing, and certify in writing that all copies thereof in its possession have been returned and/or destroyed. 
      6. This Section ‎10 shall survive any termination of this Agreement.
  • Privacy 
      1. Each Party hereby represents, warrants and undertakes (i) that its collection and transfer of any personal data collected or transferred hereunder (including, with respect to Customer, the Customer Data and Feedback) does not infringe or violate any third party’s privacy rights or any Applicable Law; and (ii) to comply in connection with this Agreement, with all privacy and data protection laws and regulations applicable to it. 
      2. Any Customer Data shall be stored and processed by Circles in accordance with the Privacy Policy.
  • Intellectual Property
      1. Other than as provided in this Agreement, Circles shall not acquire (and hereby irrevocably disclaims) any rights, title or interest in or with respect to the Customer Data, and all rights (including all Intellectual Property Rights) therein are retained solely by Customer.
      2. Other than the right to use the Services in accordance with this Agreement hereof, Customer shall not acquire (and hereby irrevocably disclaims) any rights, title or interest in or with respect to the Software and/or the Documentation and/or any other inventions and/or improvements developed by Circles using the Customer Data (including but not limited to the Feedback), and all rights (including all Intellectual Property Rights) therein are retained solely by Circles.
      3. Customer shall not make use of any Intellectual Property Rights belonging to Circles with respect to the Software, including any trade-marks, trade-names, domain-names or other such marks associated with the Software, unless explicitly and specifically approved by Circles in advance.
      4. This Section ‎12 shall survive the termination of this Agreement.   
  • Third Party Software

The Software may contain third party, including open source, software (“Third Party Software”) that may be subject to third party terms and conditions (“Third Party Terms”). To the extent of any conflict between any Third Party Terms and this Agreement or conditions of this Agreement, the Third Party Terms shall prevail in connection with the corresponding Third Party Software (but only to the extent of the conflict). Notwithstanding anything contained in this Agreement to the contrary, Circles does not make or offer any representation or warranty, and does not undertake any defense or indemnification obligation or liability, with respect to any Third Party Software. 

  • Disclaimer of Warranties 
      1. Circles shall use reasonable efforts consistent with prevailing industry standards to maintain the Services in a manner which minimizes errors and interruptions in the Services and shall perform the Services in a professional and workmanlike manner. Services may be temporarily unavailable for scheduled maintenance or for unscheduled emergency maintenance, either by Circles or by third-party providers, or because of other causes beyond Circles’ reasonable control. 
      2. EXCEPT AS EXPRESSLY SET FORTH IN THIS AGREEMENT, NO WARRANTY, EXPRESS OR IMPLIED, IS MADE WITH RESPECT TO THE SERVICES, INCLUDING WITHOUT LIMITATION, ANY INPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR ANY PARTICULAR PURPOSE, INCLUDING FOR ANY PURPOSE RELATING TO THE SERVICES, OR ANY NONINFRINGEMENT OF THIRD PARTY RIGHTS. THE SERVICES ARE PROVIDED “AS IS” AND NO WARRANTIES ARE MADE THAT USE OF THE SERVICES WILL BE ERROR FREE OR UNINTERRUPTED, OR THAT ANY ERRORS IN THE SERVICES WILL BE CORRETED, OR THAT THE SERVICES WILL MEET CUSTOMER’S REQUIREMENTS, NOR DOES IT MAKE ANY WARRANTY AS TO THE RESULTS THAT MAY BE OBTAINED FROM USE OF THE SERVICES.
  • Limitation of Liability 
      1. IN NO EVENT SHALL CIRCLES, ITS SUPPLIERS (INCLUDING BUT NOT LIMITED TO ALL EQUIPMENT AND TECHNOLOGY SUPPLIERS), OFFICERS, AFFILIATES, REPRESENTATIVES, CONTRACTORS AND EMPLOYEES OR ANYONE ON ITS BEHALF, BE LIABLE FOR ANY INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, LOST PROFITS, ARISING IN CONNECTION WITH THE USE OF THE SERVICES, ANY INTERRUPTION IN AVAILABILITY OF THE SERVICES, DELAY IN OPERATION OR TRANSMISSION, VIRUSES, LOSS OF DATA, OR USE, MISUSE, RELIANCE, REVIEW, MANIPULATION, EVEN IF THE POSSIBILITY OF SUCH DAMAGES OR LOSS HAS BEEN ADVISED IN RELATION TO ONE OR MORE OF THEM. THIS LIMITATION OF LIABILITY APPLIES IRRESPECTIVE OF WHETHER OTHER PROVISIONS OF THIS AGREEMENTHAVE BEEN BREACHED OR HAVE PROVEN INEFFECTIVE. 
      2. WITHOUT DEROGATING FROM THE FOREGOING, CIRCLES’ TOTAL CUMULATIVE LIABILITY UNDER, OR OTHERWISE IN CONNECTION WITH, THIS AGREEMENTSHALL NOT EXCEED THE AMOUNT OF FEES PAID BY ONEDEGREE TO CIRCLES IN THE 12 MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO SUCH LIABILITY.
  • Indemnification 
      1. Customer hereby agrees to indemnify and hold harmless Circles against any damages, losses, liabilities, settlements and expenses (including without limitation costs and attorneys’ fees) in connection with any claim or action that arises from an alleged violation of this Agreement or Applicable Law by the Customer in connection with its use of the Services.
      2. Circles shall hold Customer harmless from liability to third parties resulting from infringement by the Services of any Intellectual Property Rights of third parties.  The foregoing obligations do not apply with respect to portions or components of the Services (i) not supplied by Circles, (ii) made in whole or in part in accordance with Customer specifications, (iii) that are modified after delivery by Circles, (iv) combined with other products, processes or materials where the alleged infringement relates to such combination, (v) where Customer continues allegedly infringing activity after being notified thereof or after being informed of modifications that would have avoided the alleged infringement, or (vi) where Customer’s use of the Services is not strictly in accordance with this Agreement.  If, due to a claim of infringement, the Services are held by a court of competent jurisdiction to be or are believed by Circles to be infringing, Circles may, at its option and expense (a) replace or modify the Services to be non-infringing provided that such modification or replacement contains substantially similar features and functionality, (b) obtain for Customer a license to continue using the Service, or (c) if neither of the foregoing is commercially practicable, terminate this Agreement and Customer’s rights hereunder and provide Customer a refund of any prepaid, unused fees for the Services.
      3. The indemnifications of this Section ‎16 are conditioned upon the indemnified party: (i) providing the indemnifying party with prompt written notice of any claim which the indemnified party seeks to be indemnified, defended or held harmless under this Agreement; (ii) granting the indemnifying party full authority and control over the defence and settlement of any such claim; and (iii) reasonably cooperating, including actions aimed at the mitigation of damages, with the indemnifying party and its agents in defence of any such claim. The indemnified party shall have the right to be represented in any suit or action by advisory of its selection at its expense.
  • Miscellaneous
    1. Circles may state in its website or otherwise the fact that the Customer is a client of Circles, and may otherwise utilize the Customer’s name or trademark for publicity purposes.
    2. The relationship of the parties hereto is that of independent contractors. Nothing contained in this Agreement is intended implicitly, or is to be construed, to constitute Customer or Circles as partners or joint venturers in the legal sense. No party hereto shall have any express or implied right or authority to assume or create any obligations on behalf of or in the name of any other party or to bind any other party to any contract, agreement or undertaking with any third party.
    3. A party may not assign any rights or obligations under this Agreement without the prior written consent of the other party, and any such attempted assignment without prior written consent shall be deemed null and void. Notwithstanding the foregoing, Circles may assign all of its rights and obligations under this Agreement to any of its affiliates and/or to any third party which purchases substantially all of its assets and/or into which it is merged. 
    4. If any provision of this Agreement is held to be invalid, illegal or unenforceable for any reason or in any respect whatsoever, such invalidity, illegality or unenforceability shall not affect any other provisions of this Agreement, and this Agreement shall be construed as if such invalid, illegal or unenforceable provision had never been contained herein. 
    5. Any failure to enforce any provision of this Agreement by a party shall not constitute a waiver thereof or of any other provision hereof, and any waiver by a party of any breach or default by the other party shall not constitute a waiver of any different subsequent breach or default. All waivers shall only be effective if made in writing and signed by the Party making the waiver.
    6. This Agreement, shall constitute the sole and entire agreement between the parties, with respect to the subject matter of this Agreement, and shall supersede any and all prior agreements, whether oral or written. 
    7. Circles reserves the right, at its sole discretion, to amend these Terms of Service at any time and will notify Customer of any material changes to these Terms of Service, at least 30 days in advance, by posting a notice on the Service or sending email to the primary email address specified in the Customer’s account. Customer’s continued use of the Service after those 30 days constitutes agreement to those revisions of these Terms of Service. For any other modifications, Customer’s continued use of the Service constitutes agreement to our revisions of these Terms of Service.
    8. This Agreement will be governed exclusively by, and construed exclusively in accordance with the laws of the State of Israel, without regard to the conflict of law provisions thereof. Any dispute arising under or in relation to this Agreement shall be resolved in the competent courts of Tel Aviv-Jaffa, and each of the parties hereto hereby irrevocably submits to the exclusive jurisdiction of such courts. 
    9. Any notice or other communication to be made or given by one party to the other under this Agreement shall be in writing and shall be delivered by hand, transmitted by e-mail or sent by prepaid registered mail to the party to whom the notice is given, transmitted or sent, at its address set forth in the preamble to this Agreement. A notice shall be deemed to have been served: (i) if delivered by hand, when actually delivered; or (ii) if sent by email, the next business day after receipt of confirmation of transmission; or (iii) if sent by mail, 72 hours after being mailed by registered mail, postage prepaid.

 

Last updated: November, 2021

Privacy Policy

Welcome

Welcome to the privacy policy of Circles (the “Policy”).

This Policy explains how we collect, process, use, transfer, share and retain information about users in connection with our website (the “Website”) and our innovation platform where users can create an innovation ecosystem, share ideas and response to other users’ ideas (the “Platform”).

In this Policy, “Service” means and includes the Platform and the Website.

The Service is owned and operated by CIRCLES IT INNOVATION LTD. (“we”, “our”, “us”, “Circles”).

If you do not agree to the terms of this Privacy Policy, please immediately stop using the Service. 

This Policy applies to any browsing, visiting, downloading, creating a user account, uploading of information in various forms, such as textual, visual, audio or any combination thereof, or any other act or use in connection with the Service (collectively, the “Use”). 

There is no legal obligation to consent to the transmission, collection, production, processing, storing or other use of the information (as described below).

By browsing, or otherwise using the Service, you voluntarily agree to this Privacy Policy in its entirety, and to the collecting, storing, transmitting, processing, using and producing such information, and otherwise using of the information as set forth in this policy.

You declare that you are at least 18 years of age. 

This Policy is incorporated by reference into the Service’s Terms of Use [link to the Terms]. (the “Terms”) and constitutes an integral part of the Terms.

Information we collect 

Authentication and creating a User Account. To create a user account (“User Account”), you will be asked to provide us with your full name, your email account, password, and your  organization name. 

Content that you post on or to the Service may contain, or be indicative of, your information, depending on the particulars of the content (“User Content”). Such User Content is not treated as private and you should not have any expectation of privacy or confidentiality with respect to it, as it may be available to other users of the Service.

BECAUSE THE USER CONTENT YOU UPLOAD MAY HAVE TO DO WITH THE PRIVACY OF OTHERS, YOU MUST LAWFULLY OBTAIN THE CONSENT OF ALL INDIVIDUALS (AND THE CONSENT OF THE PARENTS OR LEGAL GUARDIANS OF ALL MINORS), WHO ARE DEPICTED, SHOWN OR REFERRED TO IN THE USER CONTENT, TO INCLUDE THEM IN THE USER CONTENT AND TO USE THAT USER CONTENT FOR THE PURPOSES AND IN THE MANNER CONTEMPLATED BY THIS POLICY AND THE TERMS. 

IN ANY CASE, USE CAUTION AND COMMON SENSE WHEN YOU UPLOAD USER CONTENT CONTAINING OR DEPICTING INFORMATION ABOUT YOU OR OTHERS. YOU ARE SOLELY RESPONSIBLE FOR ANY USER CONTENT THAT YOU UPLOAD.

Contacting us. To contact us via e-mail, you may be required to provide us with information, such as your name and contact details. 

You must provide complete, accurate and correct details. If you do not provide the required information, or provide false, incorrect, or outdated information, we may not be able to process your request or inquiry or contact you. We may also require additional information from you, to verify your account and identity. 

We automatically collect Analytical data and Device Information. We may automatically collect information about your use of the Service. For example, we may record the frequency and scope of your use of the Service, the duration of your sessions, the interactions and communications you make with the Service’s interface, and Content or User Content that you view or create while using the Service. We may collect information regarding monitoring surfing habits, usage data, information and advertisements you have viewed, web pages you have browsed, and Information from social networks. We may also automatically collect information about your personal computer or mobile device, including its model, operating system, unique device identifiers, mobile network information and the Internet Protocol (IP) address through which you accessed the Service.

Children’s Privacy

We do not knowingly or intentionally collect information regarding minors. If you are a minor, you may not use the Service and may not provide any details to us. 

Use of Collected information 

We use the information we collect for the following purposes:

  • To operate and facilitate the access to and use of the Service, its features and functionalities, develop, improve and customize the Service, to manage the administrative and operational aspects of the Service; 

  • To assess your entrepreneurship skills and work with you to help you develop your skills.

  • To draw conclusions in order to improve and encourage innovation processes within the organization.

  • Send you administrative updates and announcements, provide you with support, handle complaints and contact you when we believe it to be necessary, either directly or through others on our behalf, including by e-mail messages;

  • Send you newsletters and marketing messages (which you may opt-out of by following the instructions within such messages, or by contacting us via the details in this policy);

  • Enforce the Terms and this Policy and prevent unlawful activities and misuse of the Service; 

  • Comply with any applicable law and assist law enforcement agencies and competent authorities, when we have a good faith belief that our cooperation with them meets the applicable legal standards; and 

  • Take any action in any case of dispute involving you, with respect to the Service. 

Sharing collected information 

We share information outlined in this Policy, with others, in the following instances: 

  • User Content that you upload on to the Service will be shared with, and viewable by, other users of the Service from your organization. 

  • With our service providers (including through “Cloud Services“), in order to operate, maintain and enhance the Service. 

  • In order to personalize third-party advertising and various content for you.

  • If you have breached the Terms, abused your rights to use the Service, or violated any applicable law, your information may be shared with competent authorities and with any third party, as may be required;

  • With third parties to whom we believe that we are required by law to disclose your information; 

  • With attorneys, courts and relevant third parties, in any case of a dispute, or legal proceeding of any kind involving you with respect to the Service; 

  • If the operation of the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided that those entities agree to be bound by the provisions of this Policy, with reasonable necessary changes taken into consideration; and

  • We may share information with our corporate group entities (companies that we control, control us, or are under common control with us – whether directly or indirectly), but their use of such information must comply with the Policy.

In any case other than the above, your information will be shared with others only if you provide your prior consent.

Retaining and controlling the information

Information retention. We retain the information we collect for as long as we deem necessary for our business needs, and delete it thereafter from our systems, without notice to you. Please remember that the Service does not provide back-up services for any Content. 

Accessing, updating or deleting your information. you may ask to access the information that was collected about you, that is stored in our databases, and which is identified and associated with you. 

Subject to the limitations in law, you may request that we update, correct or delete inaccurate or outdated information. 

If you wish to exercise any of these rights, contact us at: info@circles.so 

When handling these requests, we may ask for additional information to confirm your identity and your request. 

Even if we delete or amend your information, or grant your request in any other manner, we will continue to keep information we require in order to operate the Service and our business as well as information required to defend and protect our legal rights, to comply with regulatory requirements, to prevent deception or fraud, and for the enforcement of this Policy and the Terms.

Anonymization

At any time, we may anonymize (de-identify) any information we have collected. We may use the de-identified information (and/or aggregated information) in any way, including by selling, or making it available, to any other third party, and for any purpose. 

Data Owner (controller) and Data processor

We are the “Data Owner” (controller) only of information relating to the users of our Website.

All information which will be uploaded to the Platform or will be collected in connection with the Platform, will only be processed by us on behalf of our customers (“Customer” means person or entity that enters into an applicable Order Form with us). In such instances, our customer shall be deemed the “Data Owner” (controller) of such information, and we will process such information on the customer’s behalf, as its “Data processor”. In the event that our relationship with our customer is cancelled or terminated, we may keep and use only aggregated, and/or anonymized and/or de-identified information.   

For more details regarding our policy and activities as “Data Processor”, please see: [Link]

Commercial messages

BY SUBMITTING YOUR CONTACT DETAILS, YOU PROVIDE US WITH YOUR EXPRESS CONSENT TO RECEIVE COMMERCIAL MESSAGES, INCLUDING DIRECT MAILING AND MARKETING COMMUNICATIONS, FROM OUR CUSTOMERS, FROM THE COMPANY, FROM CIRCLES OR OTHERS ON ITS BEHALF. AT ANY TIME, YOU MAY WITHDRAW YOUR CONSENT AND NOTIFY US THAT YOU REFUSE TO RECEIVE SUCH MESSAGES, ALTOGETHER OR OF SPECIFIC KIND, BY SENDING A NOTICE OF CONSENT WITHDRAWAL. THE CHANNELS THROUGH WHICH YOU MAY SEND SUCH NOTICE WILL BE DETAILED IN THE COMMERCIAL MESSAGES SENT TO YOU BY THE COMPANY OR OTHERS ON ITS BEHALF. 

Cookies

We and our third-party website analytics provider may use cookies on the Service. Cookies are packets of information sent by our servers to your web browser and stored in your device’s memory. The cookies may contain information, such as your interactions with the Service’s features and functionality, your session durations and IP addresses, surfing habits and the pages you have visited. We use the cookies to collect analytical information about your use of the Service, adjusting the Website to your personal preferences, monitoring surfing habits and activities, surfing history, characterizing your usage of the Website, improving our service and user experience, advertising and marketing tailored to your preferences, information security, and other purposes. 

Cookies are saved on your computer’s hard drive. If you wish to block cookies, you may do so through your browser’s settings. Please refer to the browser’s help menu for further information. HOWEVER, BEAR IN MIND THAT DISABLING COOKIES MAY ADVERSELY AFFECT YOUR USER EXPERIENCE ON THE SERVICE.

 

For more details about cookies, and the different options available for disabling or deleting cookies, please refer to the instructions in the browser you are operating to use the Website, including:

 

Google Chrome browser:

https://support.google.com/chrome/answer/95647?hl=en

 

Microsoft Internet Explorer Browser:

https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer

 

Apple Safari Browser:

https://support.apple.com/en-il/guide/safari/manage-cookies-and-website-data-sfri11471/mac

 

Other systems operate on the Service which collect information about users of the Service, monitor their activities, including: pixels, “web beacons” and other means. These tools monitor website usage, scope of use, frequency of use, access sources and other details. The information collected through these tools is designed to tailor the content of the Website as per your preferences and fields of interest, as well as for the purposes of analyzing, advertising and marketing, managing and improving your experience when using the Service, segmenting research and monitoring 

 

One of the systems that operates on the Service is the Google Analytics system, which collects information about users’ surfing habits. For more details on this system, please see these links: https://policies.google.com/privacy?hl=en-US, and: http://www.google.com/analytics/terms/us.html. For options on restricting this system, see the link: https://tools.google.com/dlpage/gaoptout

Transfer of information outside of Israel and/or your territory

We may store and process information in various locations throughout the globe, including out of the borders of Israel. We may also process information using cloud services. In certain cases, the laws in some of these countries may provide a lower degree of data protection than the laws of your own country. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services. 

Information security

We use measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, it is not guaranteed, and you cannot reasonably expect that the Service and its related databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or any other kinds of abuse and misuse.

Any use of the Service could expose you to a variety of dangers associated with using the Internet, such as computer or mobile phone penetration, viruses, malware, etc. We recommend that you install adequate security software and security means before using our Service.

Changes to this Privacy Policy

We may change this Policy, but putting you on notice of such changes. The most up-to-date Policy is accessible on our Website. If you do not agree to the amended Policy, we may cancel your User Account and terminate your use of the Service. 

Contact Us

You may contact us at by: info@circles.so regarding any questions about this Privacy Policy, or with respect to our Service,  and for the purpose of exercising your rights, or in any other matter relating to the information or information security.

Last Updated: November, 2021

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DATA PROCESSOR STATEMENT

In this Statement, we, CIRCLES IT INNOVATION LTD (the “processor” or “we“), describe how we process information, when we act as “Data Processor” on behalf of our Customers. 

The meanings of all the terms in this Statement are as defined in our Privacy Policy. 

In this Statement “Customer Information” means identifiable information regarding users that relate to the Customer (employees, students, members, advisors, etc.), which was collected as part of the use of the Platform. 

To avoid any doubt, information that was collected as part of the use of the Website, is not Customer Information.

 

  1. Processing of Customer Information

 

  1. The processor will process Customer Information, only for the purpose of providing the Service.

 

  1. In order to provide the Service, the processor will carry out the processing activities of retention and processing of the Customer Information.

 

  1. We will refrain from any use of the Customer Information for any purpose not necessary and required to provide the Service to the customer.

 

  1. We will ensure that the access to any Customer Information, will be granted only to a person who has been authorised for such purpose. 

 

  1. The processor will delete and destroy all Customer Information as soon as it becomes aware that it no longer requires the Customer Information for the provision of the Service. 

 

  1. Confidentiality Undertaking

 

The processor, including its employees and any other person on its behalf, will retain Customer Information in confidentiality, not disclose Customer Information nor transfer it to any third party,save, to the extent required, to provide the Service. We will ensure that any entity granted access to the Customer Information sign an undertaking to keep strictly confidential and protect the privacy and data security of the information.

 

  1. Reporting and Supervision

 

  1. The customer and/or any other person on its behalf will be entitled to perform a reasonable audit, subject to Circles supervision on a date to be agreed upon between the parties, with respect to the provision of the Service in order to ensure the fulfilment of all of the obligations of the processor herein regarding data protection. 

 

  1. The processor will notify the customer in writing within a reasonable period of time, upon becoming aware of any of the following events regarding Customer Information: severe security incident and/or leakage of information and/or severe use that deviates from the authorisation given.

 

  1. The processor will update the customer of every approach, letter or response that may be received by the processor regarding a request to inspect Customer Information or to amend Customer Information. 

 

  1. Miscellaneous

 

  1. In the event that the relationship between the parties is terminated for any reason, the processor will deliver to the customer all Customer Information in its possession or under its control and will destroy, burn and delete any copy of Customer Information in its possession or under its control, save for any copies of Customer Information that it may keep to protect its rights and as may be required by law.

 

  1. If the processor will desire to contract with third parties, and in so doing require that such third parties be granted access to Customer Information, then the processor will include within the ambit of the agreement to be entered with any third party, substantially all of the obligations detailed herein.

 

  1. Data Security

 

We will take reasonable security measures and actions, for the purpose of securing the Customer Information. We will secure the Customer Information in accordance with the risks involved and using appropriate means, including, inter alia, implement the measures, procedures and data security requirements as set forth below:

 

  1. Physical Security

The processor will implement reasonable measures for physically protecting the systems through which Customer Information is processed and the infrastructure of such system (hereinafter, collectively – the “System”), against surrounding risks, penetrations and vulnerability.  

 

  1. Logical Security

The processor will implement appropriate security measures for the prevention of intentional or inadvertent penetration to the System and/or to the lines of communication between the owner and processor.  

 

  1. Separation of Databases 

The processor will separate the systems used by it for the purpose of performing the agreement (which contain Customer Information), from the other systems used by the processor in the ordinary and regular course of business.

 

  1. Decommission Policy

The processor will implement a decommission policy in respect of the magnetic and optic media, including hard disks, portable or detachable storage means, back up means etc., that contain personal information.  

 

  1. Procedures

The processor will implement procedures for database management, and the classification and provision of access authorisations to personal information, as well as provisions for the collection, marking, verification, processing and distribution of Customer Information and any other procedure required by applicable law. 

 

  1. Management of Authorisations

The processor will manage the access authorisations to the Customer information (including restrictions), including that access to Customer Information will only be granted to employees and/or any person on behalf of the processor who has a real need for access to Customer Information for the provision of the Service, and that each such employee and/or person will receive the minimal access required to perform his job.

 

  1. Operation, Control, Recovery and Rehabilitation

 

The processor will ensure that the System is operated while assuring data security and the preservation of the completeness of the Customer Information. In addition, the processor will implement control arrangements to detect any impairment to the completeness of the Customer Information and to correct deficiencies.

 

 

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