Privacy Policy

1. PREAMBLE AND DEFINITIONS

1. Sign Now Ltd (“Sign Now”, “we”, “our” or “us”) provides this privacy policy, as may be updated from time to time according to the terms set forth herein (our “Policy” or “Privacy Policy”), to inform you of our policies and procedures regarding the way we Process Information when you Use our Website and/or otherwise interact with us.

2. Please read carefully the terms of this Privacy Policy and make sure that you agree to be bound by its terms. If you have further questions or concerns regarding this Privacy Policy, please contact us at: tomer@signow.org.

3. Definitions:

1. "Anonymized Information" shall mean any information, data or content which is collected by Sign Now about the User's Use of the Website, which is anonymous and/or does not personally identify a User and/or reveal the User's specific identity as an individual, and/or cannot be attributed to a User. Types of Anonymized Information are detailed in Section ‎7.1 below.

2. "Consumer" shall mean an individual person who has a hearing disability and Uses the Services via the Website.

3. "Consumer Information" shall mean (a) any Personal Information the Consumer uploads to the Website in order to use the Services, or provide us when contacting us, or otherwise requires us to complete on its behalf; and/or (b) any Personal Information we collect from Third Parties, subject to the Consumer's consent; and/or (c) any Personal Information we automatically collect and/or otherwise generate from the Consumer's use of the Website, all, as detailed in sections ‎3 - ‎4 below.

4. "Information" shall mean Personal Information and Anonymized Information, together.

5. "Israeli Law" shall means the Israeli Privacy Protection Law (1981) and any applicable regulations promulgated thereto (including any amendments to such Law or such regulations) and binding guidelines issued by the Privacy Protection Authority in Israel, all – to the extent applicable to the use of Personal Information by Sign Now under this Privacy Policy.

6. "Personal Information" shall mean any "information" and/or "sensitive information" as these terms are defined in Israeli Law.

7. "Use" shall mean accessing and/or viewing and/or visiting and/or browsing the Website for any purpose.

8. "User" or "you" or "your" (including any alterations thereof) shall mean the Consumer and/or the Interpreter that: (a) Uses the Website for any purpose, using a computer and/or any other device, including cellular device and/or by any other means of communications, (b) otherwise interact with us in any other medium.

9. "Session" shall mean a triple communication between the Consumer, Interpreter and the Service Provider(s) as part of the Services. The Communication between the Consumer and Interpreter shall be video communication, and between the Interpreter and Service Provider(s) - video and/or audio communication.

10. "Services" shall mean the creation of a Session, in order to enable a Consumer to communicate with certain store, shops or other place(s) of business, service provider(s) and/or competent state and/or municipal authority(ies) (collectively the "Service Provider(s)"), for any purpose, by using the Interpreter as an intermediate between the Consumer to such Service Provider(s).

11. "Interpreter" shall mean a professional Individual who is in the business of sign-languages interpretation service, and has all relevant qualification and certifications.

12. "Interpreter Information" shall mean Personal Information that: (a) the Interpreter uploads to the Website for any purpose; and/or (b) we collect automatically and/or otherwise generate from or about the Interpreter's use of the Website; and/or (c) we receive from Consumer about the Interpreter following a completion of a Session, all as detailed in sections ‎3 - ‎4 below.

13. "Third Parties" shall mean any third party (such as center for blind persons to which you are associated to, health organizations, other person who has a hearing disability, etc.) which provides Sign Now certain Consumer Information, based on Consumer's request and/or consent.

2. WHEN DOES THIS PRIVACY POLICY APPLY

1. This Privacy Policy applies to the processing of User's Personal Information by Sign Now, when the User uses the Website and/or otherwise interact with us. If the User is an Interpreter, additional terms may apply, as detailed in the agreement entered into between Sign Now and the Interpreter. Please note that this Privacy Policy does not apply to any service which is provided by an Interpreter to a Consumer outside the scope of the Website.

2. We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Information (including when you Use the Website), and the provision of it is solely based on your free will. However, if such Personal Information is necessary for the creation of your User Account or for providing you with the Services via the Website, such decision may limit your ability to use the Website (whether in whole or in parts) and/or the Services. For more information about your rights, please see section ‎‎10 below.

3. THE TYPES OF PERSONAL INFORMATION YOU PROVIDE

1. We collect two types of data and information: Personal Information and Anonymized Information. As for Personal Information, the collection is further divided to two parts: Consumer Information and Interpreter Information. In any event, the collection of Information commences on the earlier of your first Use of the Website and/or the Services, or your approach to us in other medium.

2. When you first use the Website, you will be asked to provide some informative details about yourself in order to create your User Account. Such informative details may inter alia include some Personal Information, as detailed below (and may be updated from time to time):

1. If You are an Interpreter, the Interpreter Information in your User Account may include: basic contact details (such as your email and residence address, full name, phone number), your date of birth, i.d. number, your bank account number, seniority and expertise in sign-language interpretation services (including your expertise in specific language(s)) and relevant certification);

2. If you are a Consumer, the Consumer Information in your User Account may include: basic contact details (such as your email address, full name, phone number), i.d. number, your date of birth, your preferred sign-language, the center for blind persons to which you are associated to, formal approval issued by the National Insurance and/or applicable authorities, enabling you to receive state services, and other types of Personal Information we received from Third Parties.

As a Consumer, you may independently upload such Consumer Information in the Website. Alternatively, we may create your User Account for you per your request, if you contacted our customer success (outside the scope of the Website, such as via Whatsapp© application, Facebook©'s conversations, etc.), or if you gave us your consent to contact Third Parties, and receive such Consumer Information from them, on your behalf, as further detailed in section ‎4.3.2 below.

3. In the course of the Services, you may provide and/or otherwise upload to the Website additional Personal Information:

3. If you are an Interpreter - your Interpreter Information may further include any information you choose to transfer, disclose, reveal and/or otherwise visualize in a Session such as relevant certifications, and written Session summary submitted by you (which may include your Personal Information, if you chose to disclose such data in your summary).

4. If You are a Consumer –

1. Your Consumer Information may further include any information you choose to transfer, disclose, reveal and/or otherwise visualize in a Session, such as formal approval(s) issued by the National Insurance and/or other competent authorities, enabling you to receive state services.

2. Written Session summary submitted by you (which may include your Personal Information, if you chose to disclose such data in your summary).

4. THE TYPES OF PERSONAL INFORMATION WE COLLECT OR GENERATE

1. In addition to the Personal Information you provide us, we may also collect or generate Personal Information about you and/or your use of the Website and/or in the scope of your interaction with us. We may also receive Personal Information about you from Third Parties, and we will use and process it according to the terms herein. The collection of such Personal Information will be executed, inter alia, by using technological tools as set forth in section ‎7.2 below.

2. If you are an Interpreter - The types of Interpreter Information that we may collect/generate/receive may include (and may be updated from time to time):

1. Text messages, video and/or audio recording (including your appearance and your voice, as captured and recorded on a Session);

2. Personal Information which may be transferred via WhatsApp© and/or Facebook© conversations

3. Consumer's rating on Interpreter's performance in the Session;

4. General geographical location.

3. If you are a Consumer - The types of Consumer Information that we may collect/generate/receive include (and may be updated from time to time):

1. Text messages, video recording (including your appearance as captured and recorded in a Session, and other information transferred via Whatsapp© and/or Facebook© conversations);

2. Personal Information we receive from Third Parties, – only if and to the extent you provided us your informed consent to approach such Third Parties for this purpose;

3. Internet Protocol and general geographical location;

4. Your Personal Information which is embedded in the Services (such as the reason for approaching a Service Provider(s), telephone numbers to which you dialed in order to start a Session, and any associated Personal Information recorded in the Session.

5. HOW WE USE YOUR PERSONAL INFORMATION

1. We will store, use and/or otherwise process your Personal Information for one or more purposes as set forth below:

1. To complete User registration to the Website (and creating User Account), and identify User when re-enters the Website (inter alia to use the Services);

2. To communicate with the User (such communication will be tailored to the type of User), personalize User's experience with the Website, better understand User's needs and obtain its feedback regarding the Website and/or Services and User's experience. With respect to Interpreter – to pay for their services;

3. To provide User with service announcements and further administrative information regarding User's use of the Website and/or Services;

4. For sending direct mailing and/or marketing material (subject to your consent).

5. To transfer User's Personal Information to third party vendors, service providers, subcontractors and consultants who are working on Sign Now's behalf, in order to enable the provision of the Services and/or operation of the Website (including, without limitation, storage, hosting, process, analysis, back up purposes);

6. To enable User to the use the Website (and the Services offered via the Website);

7. For monitoring and supervision purpose of Users' interaction in a Session, including (to the extent required) for dispute resolution between a Consumer, Interpreter and a Service Provider(s);

8. To enforce this Privacy Policy and the Website's terms of use, and any other Sign Now's internal policies and procedures;

9. For statistical monitoring, cross-checking and analysis on an aggregated basis in order to improve our Website and/or Services, and for machine-learning purposes;

10. For on-going adaptation and secure Sign Now's systems against current and future attacks;

11. To comply with and in order to asses compliance with applicable laws, rules and regulations.

6. HOW WE COLLECT PERSONAL INFORMATION

We may collect and/or generate Personal Information from various sources:

2. From you – when you submit, upload and/or otherwise provide us with your Personal Information when you Use the Website and/or the Services (including when you allow us to have access to certain tools which are installed in your mobile device (such as your mobile device microphone, camera) or otherwise interact with us; We also collect Personal Information (audio and video) that is captured and recorded in a Session.

3. From Third Parties, subject to your consent; If you are an Interpreter – from the Consumer's feedback after completion of a Session. We may receive and generate Personal Information via technological tools embedded in the Website and/or Services, as further detailed in section ‎7.2 below.

7. ANONYMIZED INFORMATION

1. Collection of Anonymized Information. Further to the collection of Personal Information, we may also collect and/or generate and/or otherwise process Anonymized Information, such as:

1. User's technical device/computer details and characteristics (such as device/computer model, operating system version, browser type);

2. User's interaction history (i.e. list of past Sessions, including their durations and date, without any Personal Information incorporated therein);

3. Statistical information and/or analysis as for the reason(s) a Consumer approaches Service Provider(s), (for example: categories of Service Provider(s) the Consumer approached to; the percentages of Consumers that approached specific Service Provider(s)'s sectors. The foregoing information excludes Personal Information.

2. How we collect Anonymized Information. We may use "Google Analytics" in order to collect Anonymized Information, and reserve the right to use other technological tools in order to collect such information. If required by law, we will elaborate such tools in a cookie policy in the Website, and send an appropriate update in the Website. For more information about Google Analytics, please view: https://policies.google.com/technologies/partner-sites. Depending on your mobile device and/or computer's settings, you may be allowed to refuse the use of such tool. However this may affect your ability to use Website (whether in whole or in part) including the access and use certain feature.

3. How we use Anonymized Information. We may use Anonymized Information for the purpose detailed in section ‎5.1 above, and also for : (i) monitor and analyze User's use of the Website and/or the Services and, if required, for the technical administration and troubleshooting of the Website and/or the Services; (ii) for commercial research and further development; (iii) improving the Website and/or Services by creating system analytics, data analysis (including, by using artificial intelligence such as machine learning method) and statistical data; (iv) for any other legitimate purpose(s).

4. It is hereby clarified that if and to the extent any Anonymized Information detailed under sections ‎7.1.1 – ‎7.1.3 above will be considered as Personal Information, , we will not use it without receiving your opt-in Consent and/or other have lawful basis for such process activity.

8. DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

We may share, disclose and/or otherwise transfer the Information to third parties, as follows:

5. With third party's service providers (such as cloud service providers, subcontractors, and consultants) which assist us in the operation and the on-going activity of the Website and/or the Services derived therefrom, as detailed in Section ‎5.1.5 above. These third parties will be subject to appropriate data protection obligations.

6. To the extent required in order to comply with any applicable law, regulations or legal requests and assist law enforcement authorities. We may further disclose Information that we believe in good faith that disclosure of Information is necessary to prevent imminent physical harm, financial loss or to report suspected illegal activity. In all cases, such Information will only be disclosed in accordance with applicable laws and regulations;

7. To take any action in any case of dispute involving you with respect to your usage of our Services and/or Website; and

8. In connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

9. INTERNATIONAL TRANSFER OF PERSONAL DATA

The Information is stored and/or hosted and/o processed on third party's secured servers located in the EEA and/or USA and/or other countries that may be outside of your jurisdiction, which may not offer an adequate level of protection as exists under your local laws. By providing us your Personal Information in any medium (including, without limitations, by submitting your Personal Information through the Website and/or in the Services or contacting us for any other reason, whether by yourself or via third party on your behalf), you hereby acknowledge, and provide your informed consent to such transfer, storing and/or processing of your Personal Information in such locations

10. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION.

1. We respect your rights regarding your Personal Information, and therefore taking the steps necessary to enable you the following rights: You have the right to review your Personal Information which is being stored in our database(s), and also provide a request to update, amendment and/or delete it by contacting us at tomer@signow.org. We will act in accordance with the provision of the applicable Law in order to comply with your request. However, with respect to deletion request, we may retain certain Personal Information as required for the purposes set forth in this Privacy Policy and/or as deemed necessary by the applicable law, or for legitimate Service Provider(s) reasons, for the duration as required under applicable law

2. We obligate to make all reasonable efforts to respect your request as soon as practically possible (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.

11. RETENTION PERIOD

1. We will retain your Personal Information for as long as is necessary for the purposes for which it was collected and any other permitted linked purposes. So if Personal Information is used for two purposes, we will retain it until the purpose with the longest retention period expires; but we will stop using it for the purpose with a shorter retention period once that shorter period has expired.

2. Unless otherwise restricted under applicable law, Anonymized Information will be retained indefinitely.

12. SECURITY MEASURES.

1. We take the safeguarding of the Information very seriously, and use a variety of methods to try to protect the Information from loss or unauthorized use or access when it is in our possession or control, including reasonable technical and organizational measures which restrict access to the Information. However, we do not promise that any Information will be fully protected from unauthorized disclosure or use.

2. Please note that Sign Now does not check the validity of the use of your User Account. You should take steps to protect your mobile device/computer (including any personal and/or confidential and/or sensitive information contained in it, including any Personal Information incorporated in the User's Account) and/or the confidentiality of any of your (or any individual surrounding you) content, information or data when you use the Service – as the Sessions are recorded.

13. OUR POLICY TOWARDS CHILDREN

Our Services are not meant to be used by or for persons under 18. As such, we do not knowingly collect Personal Information from minors younger than 18. If you’re under 18, you may use our Website and Services only with the involvement of a parent or legal guardian.

14. CHANGES TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy at our sole discretion. We will inform you of any such change by posting a notice in the Website. We will make an effort to inform you of substantial changes through the channels of communication generally used in such circumstances, and subject to the requirements of applicable laws - to obtain your consent. If we need to adapt this Privacy Policy to legal requirements, the amended Privacy Policy will become effective immediately or as required.

15. CONTACT US. If you have any concerns or questions about this Privacy Policy, please contact us at tomer@signow.org

Last Updated: __ November, 2022