Introduction

This Privacy Policy (“Policy”) outlines what personal information is collected by Varada Ltd (“Varada”, “we”, “us” or “our”), how we use such personal information, the choices you have with respect to such personal information, and other important information. 

From whom we collect personal information?

This Policy applies to our collection, use, and disclosure of the personal information of the following categories of individuals:

• Website Visitors: Individuals who visit our Website and who may volunteer certain contact data (such as their names, email address and phone numbers) to receive communications from us. For the purposes of this Policy, “Website” shall refer to https://www.varada.io/. For clarity, the Website does not include any sites owned or operated by our Customers. 
• Customers: Individuals who provide their personal data during the registration on any of Varada’s Services (as defined below), whether on their own behalf or on the behalf of an entity or organization that uses the Services. For the purposes of this Policy, “Services” shall refer to all products or service offerings made available by us. 

What personal information we collect?

Website Visitors: 

• Name, email address, and other contact information. We ask for and—at your option—collect your contact data (such as name and email address) from you when you submit web forms on our Website, including opportunities to sign up for and agree to receive email communications from us. We also may ask you to submit such personal information if you choose to use interactive features of the Website, including participation in surveys, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law. 
• The Tracking Technologies. When you visit or access our Website, we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags and other technologies (“Tracking Technologies“). These Tracking Technologies allow us and third parties to automatically collect information about you (such as your IP address, device unique identifiers and your online behavior), in order to enhance your navigation on our Website, improve our Website’s performance and customize your experience on our Website, as well as for behavioral advertising and fraud prevention purposes. We also use this information to collect statistics about the usage of our Website, perform analytics, deliver content which is tailored to your interests and administer services to our customers. 
• Google Analytics. Our website uses Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics employs cookies that are stored to your computer in order to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there. You can learn more in Google Privacy Policy. Google also offers Google Analytics Opt-out Browser Add-on. 
• Log Files. Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Website, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences. 

Customers: 

• Customer Account Information. When Customers register with Varada’s Services, we collect their email address and other contact data (such as first and last name). We refer to this information as “Customer Information” for the purposes of this Policy. Customer Information is required to identify you as a Customer and permit you to access your account(s). By voluntarily providing us with such Customer Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us. 

Legal basis for processing (eea only):

If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the Services you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such information under applicable laws. 

In some cases, we may need the personal information to protect your vital interests or those of another person. 

Where we rely on your consent to process your personal information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal information, you have the right to object. 

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us through the contact details available below. 

How we use your personal information?

Varada only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a general matter, for all categories of information we collect, we may use the information we collect to: 

• provide, operate, maintain, improve, and promote the Website and Services; 
• enable you to access and use the Website and Services; 
• process and complete transactions, and send you related information, including purchase confirmations and invoices; 
• send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; 
• send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners. 
• monitor and analyze trends, usage, and activities in connection with the Website and Services and for marketing or advertising purposes; 
• comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; 
• personalize the Website and Services, including by providing features or content that match your interests and preferences; and 
• process for other purposes for which we obtain your consent. 

We may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered on Varada sales submission form with information we receive from a third-party sales intelligence platform vendor to enhance our ability to market our Services to Customers or potential Customers. 

How we share your personal information?

We work with other companies who help us run our business (“Service Providers”). These companies provide services to help us store information (such as cloud storage companies), deliver customer support, process credit card payments, monitor and analyze the performance of our Services and Website, manage and contact our existing Customers as well as sales leads, provide marketing support, provide fraud prevention services, and otherwise operate and improve our Services. These Service Providers may only process personal information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations. 

Specifically, we do not permit our Service Providers to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us. 

In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances: 

• With other subsidiaries or affiliate companies of Varada; 
• With our resellers and other sales partners who may help us distribute the Services to Customers; 
• In the event of a merger, sale, change in control, or reorganization of all our part of our business; 
• When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; 
• Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Services’ agreements, or as otherwise required to comply with our legal obligations; or 
• as you may otherwise consent from time to time. 

International Information Transfers

Please note that our businesses, as well as our trusted partners and service providers, are located around the world. Any information that we collect (including your personal information) is stored and processed in various jurisdictions around the world (including in the United States), for the purposes detailed in this Privacy Policy. Please note that some data recipients may be located outside the European Economic Area (the “EEA”). In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection, on the basis of the EU standard contractual clauses or the Privacy Shield Framework. 

Data Subject Rights

If you reside in the EU (or in other jurisdiction that affords you with the below rights), you may request to: 

• Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with certain supplementary information. 
• Receive personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
• Request rectification of your personal information that is in our control. 
• Request erasure of your personal information. 
• Object to the processing of personal information by us. 
• Request to restrict processing of your personal information by us. 

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You also have a right to lodge a complaint with a supervisory authority 

Retention

We will retain your personal information for as long as necessary to operate our Website or provide Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. 

Data Security

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal information. 

While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using the Services or the Website, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the personal information you choose to disclose. 

Changes To Our Privacy Policy

We reserve the right to change this Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy through our Website or we will send you an e-mail regarding such changes to the e-mail address that you volunteered (if you have volunteered it). Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Policy are effective as of the stated “Effective Date”, and your continued use of the Websites or Services after such date will constitute acceptance of, and agreement to be bound by, those changes. 

Business Transactions

We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all our part of our business. 

Contact Information

Varada Ltd. 
Habomin 1, Ramat Gan, 
Israel 
privacy@varada.io