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Effective Date: January 2025

If-So Technologies Ltd. (“If-So”, “we”, “our” or “us”) develops and provides a WordPress plugin, designed to create an increase in your website’s engagement, conversion and sales (the “Product”). Our Product and our website (available at www.if-so.com, the “Site”) (together the “Services”), allow organizations and companies (each, our “Customer”) to individualize and specialize their websites for each of their visitors (“End-Users”), based on their profile and site interaction.

This Privacy Policy describes how we collects, stores, uses and discloses the following categories of personal data:

1. End-User Data: Personal Data (as defined below) about End-Users processed by us through our Customer’s use of the Product. Such data mainly consists of IP addresses of End-Users. We process End-User Data on behalf of the Customer and under its instructions, in accordance with our Data Processing Addendum. Accordingly, this Privacy Policy (which describes our practices as a data controller) does not apply to such processing. To learn about the privacy policy and practices of our Customer, please contact them directly.
2. Customer Data: Personal Data relating to users of our Product (“Users”) who use it on behalf of a Customer (usually, our Customer’s focal persons). Such data may contain User’s name, workplace and position, contact details (such as e-mail and phone), and account login credentials (usernames and hashed passwords), as well as any other data you choose to provide when you use our Services, create a user account or contact us.
3. Prospect Data: Personal Data relating to visitors of our Site, participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with us. 

Specifically, this Privacy Policy describes our practices regarding:

1. Data Collection
2. Data Uses
3. Data Location and Retention
4. Data Disclosure
5. Cookies and Data Collection Technologies
6. Communications
7. Data Security
8. Data Subject Rights
9. Children’s Privacy
10. Data Controller/Processor
11. Additional Notices

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services.

You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range of Services or with the best user experience when using our Services.

1. Data Collection & Processing

When we use the terms “Personal Data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual. 

We collect Personal Data regarding our Visitors and Customers. Such data is typically collected and generated through the Visitor’s or Customer’s interaction with our Services, through automatic means, directly from such Visitor or our Customers, or from other sources and third parties, such as our Service Providers, even before our first interaction. We may also collect Personal Data of other individuals (such as our Customer’s End-Users), on our Customers’ behalf during their use of our Product. We do so as our Customers’ data processor. For more information about our position with respect to data processing, please see Section 10 below.

Specifically, we may collect or generate the following types of personal data:

1. Usage, login credentials, and device information concerning Users and Prospects (connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Services, the cookies and pixels installed or utilized on their device, and inferred or presumed data on generated from their use of the Services);
2. Information concerning our Customers, Users and Prospects (contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback and testimonials received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement).
3. IP addresses of our Customers’ End-Users, processed by us on behalf of the Customer during its use of our Product. We process such data as a data processor (i.e. the respective Customer assumes the role of a data controller over such data) in accordance with our Data Processing Addendum.

2. Data Uses

We use Personal Data as necessary for the performance of our Services (“Performance of Contract"); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support, and protecting and securing our Visitors, Customers, Users, Prospects ourselves and our Services (“Legitimate Interests”).

If you reside or are using the Site in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Site, or sue to nature of such processing) (“Consent”), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your Consent to the processing of your personal data for all purposes details in this Privacy Policy, unless applicable law requires a different form of Consent. If you wish to revoke such Consent, please contact us at info@if-so.com. 

Specifically, we use Personal Data for the following purposes, and in reliance on the legal bases for processing noted next to them, as appropriate:

To facilitate, operate, and provide our Services	Performance of Contract; Legitimate Interests
To provide our Visitors and Customers with assistance and support	Performance of Contract; Legitimate Interests
To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties	Legitimate Interests
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements more effectively, including contextual, behavioral, and interests-based advertising for our own products and services, based on Visitor’s, Prospect’s and Customer’s activity, preferences or other data available to us or to our business partners, including for retargeting purposes	Legitimate Interests; Consent
To contact our Visitors, Prospects and Customers with general or personalized messages and communications, as further described under Section 6 below; and to facilitate, sponsor and offer certain events and promotions	Performance of Contract; Legitimate Interests; Consent
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 may use to provide and improve our respective services	Legitimate Interests; Legal Obligation
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services	Legitimate Interests
To enforce our Terms and Conditions, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties	Legitimate Interests
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards	Performance of Contract; Legitimate Interests; Legal Obligation

3. Data Location and Retention 

Data Location: We and our authorized Service Providers (defined below) maintain, process and store Personal Data in the United States of America (U.S.), the State of Israel and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, If-So and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

If-So is headquartered in Israel, a jurisdiction which is considered by the European Commission and the UK Secretary of State to be offering an equally adequate level of protection for personal data as is granted in the EEA and the UK, respectively. We transfer personal data from the EEA (including Switzerland) and the UK to Israel on this basis. For data transfers from the EEA or UK to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered (or will enter) into Standard Contractual Clauses as approved by the European Commission and UK ICO. 

Data Retention: We retain End-User Data in accordance with the respective Customer’s instructions and in accordance with the Data Processing Addendum. 

We retain Customer and Visitor Personal Data for as long as reasonably necessary in order to maintain and expand our relationship with them and to provide them with our Services. When a Customer uses the Product for a free trial period, we will retain the Customer Data for a shortened time period in order to provide the Services until the free trial period ends or longer, as necessary to fulfill our legitimate business interests and in accordance with our data retention policy and applicable laws requiring us to retain data.

We will also retain your Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete 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 email at info@if-so.com. 

4. Data Disclosure

We disclose Personal Data in the following ways:

Legal Compliance: 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. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own, namely - hosting, data analytics, marketing and advertising, data and cyber security, payment processing, user engagement, e-mail distribution and monitoring, text messaging and session recording; as well as our business, legal and financial 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 and enhancing our Services, and may only use it for such purposes.

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of If-So, any of our Customers, or any members of the general public.

If-So Subsidiaries and Affiliated Companies: We may share Personal Data internally within If-So’s group of subsidiaries and affiliates for the purposes described in this Privacy Policy. In addition, should If-So or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, If-So may share your Personal Data in additional manners, such as pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

5. Cookies and Data Collection Technologies

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns. 

A cookie is a small text file that is placed, for example, to collect data about activity on our Site. Some cookies and other similar technologies serve to recall Personal Data, such as an IP address, that was previously indicated.

we use Google Analytics to collect information about the use of our Site. Google Analytics collects information such as how often you visit the Site, which pages you visited when doing so, and which other sites they used prior to coming to our Site. We do not merge the information collected through the use of Google Analytics with personally identifiable data. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt out of these analytics services is available here.

To learn more about the cookies we use, please visit our Cookie Policy. 

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser and recommend the use of cookies for an optimal user experience of our Services, most browsers allow you to control cookies, including whether to accept them or to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

6. Communications

Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. We, or our Customers (your organization), may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

Notifications and Promotional Communications: We may also contact you, through email or via the Intercom app, with promotional messages (such as newsletters, special offers and sales, new product announcements, etc.) or any other information we think our Customers will find valuable; and to facilitate, sponsor and offer certain events and promotions. We may provide such notices through any of the contact means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites. 

If you do not wish to receive such promotional communications, you may notify If-So at any time by sending an email to info@if-so.com, changing your communications preferences in your account, or by following the “unsubscribe” instructions contained in the promotional communications you receive.

7. Data Security

In order to protect your Personal Data held with us and our Service Providers, and on our networks, we use industry-standard physical, procedural, and electronic security measures, as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.

8. Data Subject Rights

If you wish to exercise your rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR) or California Consumer Privacy Act (CCPA), such as – to the extent applicable – the right to know/request access to (specific pieces of Personal Data collected; categories of Personal Data collected; categories of sources from whom the Personal Data was collected; purpose of collecting Personal Data; categories of third parties with whom we have shared Personal Data), to request rectification or erasure of your Personal Data held with If-So, or to restrict or object to such Personal Data’s processing (including the right to direct us not to sell your Personal Data to third parties now or in the future), or to port such Personal Data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you) – please contact us by email at info@if-so.com. Moreover, you may correct, update or remove Personal Data and/or deactivate your account by logging into your If-So account or accessing any other website, connected to If-So, where you have provided such data. If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.

Please note that once you contact us by e-mail regarding your Data Subject rights, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity so we could further process your request. Such additional data will 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 3 above.

9. Children’s Privacy

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 prohibit and block such use and will make all 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 email at info@if-so.com.

10. Data Controller/Processor

Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), 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.

If-So is the “Data Controller” of its Prospect Data and Customer Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.

If-So is the “Data Processor” of End-User Data, as well as all generated content and further information on our Customer’s site visitors. If-So processes such data on behalf of the Customer (who is the “Data Controller” of such data; and our Service Providers who process such End-User Data on our behalf are the “sub-processors” of such data). Accordingly, with respect to End-User Data, the Customer 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).

11. EU Representative

Nofar Carmeli
9b Avenue Charles Flahaut
34090 Montpellier, France
Email: privacy@if-so.com

12. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

California Requirements: This policy describes the categories of personal information we may collect and the sources of such information (in Section ‎1 above), and our retention (Section ‎3) and deletion (Section ‎8) practices. We also included information about how we may process your information (in Sections ‎2 through ‎6), which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Section ‎4 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or direct us to disclose your personal data to third parties, or as otherwise described in Section 4 above.

If you have questions or would like to exercise your rights under the CCPA, you can contact us by email at info@if-so.com. 

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website or service you visit. This Privacy Policy applies only to our Services.

Questions, Concerns or Complaints: If you have any comments or questions about this Policy or if you have any concerns regarding your Personal Data, please contact us by email by sending us a message to info@if-so.com.