Context-Based 4 Casting, Ltd. and our affiliates (“CB4”, “we”, “our” or “us”), puts great efforts in making sure that the personal data we process is safe and used properly, and that our data practices are properly communicated to our customers and the data subjects.
(i) Prospect data concerning our prospective customers, partners or visitors who visit or engage with our websites (such as https://cb4.com/ and its subdomains), online ads and content, emails or other communications under our control (collectively, the “Sites”), or participate in events that we organize or take part in (collectively, “Prospects”);
(ii) Customer data concerning individuals (“Users”) who use CB4’s business analytics platform and services (together with the Sites – the “Services”) on behalf of our business customers (“Customers”);
- Data Collection
- Data Uses
- Data Location
- Data Retention
- Data Sharing
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Roles and Responsibilities
- Additional Information and Contact Details
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers (per Section 5 below), please avoid any interaction with us or any use of our Services.
1. Data Collection
We collect, receive and generate the following Prospect and Users data – from you, through your interaction with us or with our Services; from our Customers, who provide us with their Users’ data; or through third-party services, social media, analytics tools, events we organize or take part in, and other business initiatives.
(i) Prospect Data:
- Website usage information: connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), connectivity data, activity logs, session recordings, and the cookies and pixels installed or utilized on their device;
- Prospect account information: contact and business details and interests concerning our prospective customers and partners, which may also contain the details of their internal focal persons who may be relevant for facilitating and managing the relationship between the parties, e.g. potential business and technical owners, account administrators, billing contacts and authorized signatories; our communications with such Prospects (correspondences, call and video recordings and transcriptions, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement);
(ii) Customer’s User Data:
- Customer’s User account information: e-mail address and, when applicable, hashed password or other information used for authentication and access control;
- Profile and contact information: name, title, company, e-mail and phone number, profile picture, and additional information and media submitted by Customer’s Users or their organization;
- Service usage information: connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), communication and performance logs, issues and bugs, session recordings, user activity on our Services, and the cookies installed or utilized on the User’s device; and
- Direct interactions and communications: including messages, comments, tasks and feedback (e.g., internal communications), as well as recordings and transcripts of your calls and correspondence with us, (e.g., for user enablement, support and training purposes).
2. Data Uses
CB4 processes the personal data described in Section 1 as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services. These include understanding how our Services are used, and how our Services, campaigns and other activities are performing; gaining insights which help us dedicate our resources and efforts more efficiently; marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with.
Specifically, we use Prospect and Users personal data, for the following purposes:
- To facilitate, operate, and provide our Services, including determining your initial and continued eligibility to use our Services;
- To authenticate the identity of our Users and allow them to access and use our Services;
- To provide you with customer care, assistance and technical support services;
- To further develop, customize and improve the Services, and to improve your user experience, based on common or personal preferences, experiences and difficulties;
- To facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively;
- To contact you with general or personalized service-related messages, or with promotional messages, in accordance with Section 7 below, and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our business partners and Customers may use to provide and improve our respective services, or for any other purpose; and
- To comply with our legal, regulatory, compliance and contractual obligations.
3. Data Location
We and our authorized service providers (as detailed in Section 5 below) maintain, store and process personal data in the United States, the EU, Israel, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
4. Data Retention
We retain Prospect and User personal data for as long as it is reasonably necessary to provide our Services; to maintain and expand our relationship and provide you with our Services and offerings; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations, and where applicable, also with our Customer’s reasonable instructions and as further stipulated in our DPA and other commercial agreements with such Customer.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at email@example.com.
5. Data Sharing
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and Services.
Service Providers: we may engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), internet service providers, operating systems and platform, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, service providers that help us verify your identity and help us comply with our legal and regulatory obligations to screen and monitor transactions; and our business, legal, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.
Sharing Data with our Customers and their Users: User’s data is shared with the administrator or other Users of the same Customer account. In such cases, sharing such data means that the administrator or other Users of the account may access it on behalf of the Customer, and will be able to monitor, process and analyze the personal data contained therein. This includes instances where you may contact us for help in resolving an issue specific to you or to a team of which you are a member (and which is managed by the same Customer). Please note that CB4 is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the Data Controller of such data (as further described in Section 10 below).
Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of CB4, any of our Customers, their Users, our Prospects, or any members of the general public.
Additional Sharing: CB4 may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session – these are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, payment issues, login attempts or password reset instructions, etc. Our Customers may also use our Services to send their Users notifications, messages and other updates regarding your use of the Services.
Notifications and Promotional Communications: we may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
You can typically control your communications and notifications settings from your CB4 profile settings, or otherwise by following the instructions typically included in the communications sent to you. If you do not wish to receive promotional communications, you may also notify CB4 by sending an e-mail to: firstname.lastname@example.org.
8. Data Security
We and our hosting services implement systems, applications and procedures to secure your Personal Data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, confirmed also by CB4’s SOC 2 Type 2 compliance certification. However, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
9. Data Subject Rights
Individuals have rights concerning their Personal Data. If you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR), such as the right to request access, rectification or erasure of your Personal Data held with CB4, or to restrict or object to such Personal Data’s processing, or to port such Personal Data (if applicable) – please contact us by e-mail at: email@example.com. Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
If you would like to make any requests or queries regarding personal data that we process on our Customer’s behalf, please contact that Customer directly. For example, if you are our Customer’s User and you wish to access, rectify, or erase data processed by CB4 on behalf of our Customer, please direct your request to the relevant Customer (who is the Controller of such data – see Section 10 below). Note that if you do contact us, we may share your communications with our Customer and its Users.
10. Roles and Responsibilities
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing personal data: the “Data Controller”, who determines the purposes and means of processing; and the “Data Processor”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
CB4 is both a Data Controller and Data Processor of our Customer’s User data. Such data is processed by CB4 for our own purposes (as described in Section 2 above), as an independent ‘controller’; whilst other aspects of Users’ data will be processed by us on our Customer’s behalf, as a Data Processor. In such instances, our Service Providers processing such data will assume the role of “sub-processors”.
Accordingly, CB4 processes Users personal data strictly in accordance with such Customer’s reasonable instructions and as further stipulated in our Data Processing Addendum (DPA) and other commercial agreements with such Customer. The Customer, as the Data Controller of such data, will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
For the avoidance of doubt, each Customer is solely responsible for the security, integrity and authorized use of their Users’ information, for providing adequate notice to their Users whose personal data may be processed – including sufficient reference to the processing of their personal data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
11. Additional Information and Contact Details
Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at firstname.lastname@example.org.
EU Representative: CB4 has designated Dr. Andreas Mätzler of Prighter as CB4’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Dr. Andreas Mätzler may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to email@example.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
UK Representative: CB4 has designated Context Based 4casting Ltd. as CB4’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK-GDPR. Context Based 4casting Ltd. may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to firstname.lastname@example.org. If you are a UK-GDPR-protected individual, you also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).