Bringg's Platform Privacy Policy

Last Revised: June 12, 2018

Bringg Delivery Technologies Ltd. and its affiliates (“Bringg” or “we”) respect the privacy of its users and are committed to protect its users’ information. We believe that you have a right to know our practices regarding the information we may collect and use when you use the “Bringg Platform”, the “Bringg Driver App” and the “Bringg Dispatcher App” (the “Platform” and the “App(s)”, respectively). Please read the following carefully to understand Bringg’s views and practices regarding your Personal Information and how Bringg will treats it.

Table of Contents

1. Who we are
2. Your acknowledgement of this policy (important, please read)
3. Which information may we collect about Users?
4. How do we collect information about our Users?
5. What are the purposes of the collection and processing of information?
6. Sharing Personal Information with Third Parties
7. Your Rights
8. Location of Your Data
9. Minors
10. Third Party Service Providers and Third Party Software
11. Links to Third Party Websites
12. Cookies & Local Storage
13. Security
14. Data Retention
15. Changes to the Private Policy
16. Have any Questions?

1. Who We Are

In this policy, references to Bringg, or to “we” or “us” are to Bringg Delivery Technologies Ltd., which is a registered company in the state of Israel (No. 514938281) at 1 Habarzel st. Tel-Aviv, Israel 6971001. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at privacy@bringg.com. Our data protection officer is Lior Sion, who may be contacted at our registered address or by emailing privacy@bringg.com.

2. Your Acknowledgement of this Policy (important, please read!)

Bringg’s customers are businesses, and the Platform and Apps are intended for use solely by our customers’ authorized employees and service providers (respectively: “User” or “you” and “your Organization”). The information we collect from you via the Platform and the Apps (and thereby its process) is strictly related to your Organization and to the services that we provide to such Organization as our customer.

All information that Bringg shall collect from you and process as part of your use of the Platform and Apps, is owned and controlled by your Organization, who is the “controller” of such information (as such term is defined under EU data protection law). Please note that Bringg is acting as a data “processor” on behalf of your Organization, and that it is your Organization, in its capacity as a “controller”, which initiates the personal data collection, determines from whom to collect data and defines how to use the collected data. We will process your personal data strictly on behalf of your Organization and in accordance with our contractual agreements with it, its lawful instructions and/or as permitted by law.

For further queries, please review the privacy policies of your Organization associated with the Platform and the Apps, as applicable. If, in the context of using the Platform and/or Apps, you have reached out to your Organization and you have not received a reply, you may approach Bringg, and we will make commercially reasonable efforts to assist you.

Please note that your Organization will have the right to enforce the terms of this Privacy Policy as a third party beneficiary of this Privacy Policy. In addition, please note that your Organization may have additional privacy policy that may apply.

Please note that this Privacy Policy does not relate to data we collect from visitors of our website or any information provided to us other than through the Platform and/or App.

BY DOWNLOADING, ACCESSING AND/OR USING THE PLATFORM AND/OR APPS, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED) TO THIS PRIVACY POLICY AND TO BRINGG’S PRACTICES DESCRIBED THEREIN, INCLUDING TO THE COLLECTION, USING, PROCESSING, DISCLOSING, RETAINING OR DISPOSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DO NOT AGREE TO ANY TERM PROVIDED HEREIN, PLEASE CONTACT YOUR ORGANIZATION AND CEASE ANY ACCESS OR USE OF THE PLATFORM AND/OR APPS.

3. Which Information may we Collect about Users?

We may collect, on behalf of your Organization, two types of data and information:

      3.1. Non-personal Information. The first type is non-identifiable and anonymous information. To put it simply, we have no idea what is the identity of the User from which we have collected the Non-personal Information, unless it is cross-referenced with Personal Information. Non-personal Information, which is being gathered, consists of technical information and behavioral information. For example, technical information may include information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc. Behavioral information may include the User’s click-stream on the Platform or Apps, the activities of the User on the Platform or Apps, including information pertaining to activities made by the User and additional information of a similar nature.

     3.2. Personal Information. The other type of information we may collect is individually identifiable information. To put it simply, this information may identify an individual or is of a private and/or sensitive nature. Personal Information which is being gathered consists of any personal details provided by the User during the registration process and/or while using the Platform and/or Apps (“Personal Information”), including:

3.2.1. Personal Information which is provided voluntary:
• Activating the Platform and App: During the Platform and/or Apps activation process, you will be required to provide us with certain Personal Information, including your name, phone number and email address.
• Communications with Bringg: this relates to any information you provide to us in any communications with us, including as part of seeking customer services or as part of customer support calls. We may record your customer support calls for quality assurance purposes and in order to improve our services.
3.2.2. Personal Information collected via technology:
• Geolocation data: while using the Platform and/or Apps we will access, collect, process, monitor and/or remotely store “geolocation data”, including GPS coordinates and other similar information to determine your location in order to provide our services and for security purposes, including with respect to Users of the Bringg Driver App – such information will include the GPS coordinates of your delivery route (including shipment drop-off data and route information) or equivalent information with respect to the location of your mobile device.
• Contacts list: We may access the address book or contacts available on the mobile device from which you use the Apps, if you provide us with your permission to do so.
• We collect technical and behavioral information through your use of the Platform and/or Apps, including:
• Technical and behavioral information: to the extent that the technical and behavioral information detailed above will be linked to or associated with a specific individual then such information will be considered as Personal Information; and
• Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or another unique identifiers.
• Bringg Driver App: In connection with your use of the Bringg Driver App, we may receive data relating to your use of the phone or other voice application available on your mobile device while the App is open or is running on that mobile device, in order to determine if such use is blocking data transmission or otherwise interfering with the functionality of the App.
3.2.3. Information provided by others:
• Bringg may receive additional information about you from your Organization, as determined by the Organization. For example, in order to use the Bringg Driver App, your Organization will provide us with your mobile phone number and when you use the Bringg Driver App, your Organization will provide us with your anticipated delivery route. The scope, categories and types of information provided to us by your Organization is determined exclusively by your Organization and is subject to your Organization’s policies and your agreements with your Organization. For additional information, please refer to your Organization’s applicable privacy policies and notices.

     3.3. Please note:
• We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
• We use third-party tracking services and usage logs to track and analyze data from Users of the Portal and/or Apps and for purposes of security and fraud prevention (for more information please refer to Section 10 below). We may also use cookies to gather information regarding your use of the Portal and/or Apps and the information for which you searched and accessed (for more information please refer to Section 11 below).

4. How do we Collect Information about our Users?

These are the main methods we use to collect information:

     4.1. We collect information through your entry, connection, access and/or use of the Platform and/or Apps. In other words, when you access or use the Platform and/or Apps we are aware of your usage of the Platform and/or Apps, and may gather, collect and record the information relating to such usage. For example, when you connect to the Platform and/or Apps, your device notifies us that you are an active user. We may further log the content you generate or use your location during your use of the Apps.
     4.2. We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and activate the Platform and/or App or when you contact Bringg.
     4.3. We collect information from the device on which you use the Platform and App. For example, when using the Bringg Driver App we will continuously collect your geolocation data, including GPS coordinates.
     4.4. We collect information provided to us by your Organization. For example, when you use the Bringg Driver App, your Organization may provide us with your anticipated delivery route.

5. What are the Purposes of the Collection and Processing of Information?

     5.1. Non-personal Information is collected on behalf of your Organization in order to:

• Enhance the User’s experience on the Platform and/or Apps;
• Create statistical information and learn about the preferences of Users and general trends on the Platform and Apps (e.g. understand which features are more popular than others); and
• Keep the Platform and Apps safe and secure and for prevention of fraud;

     5.2. Personal Information is collected on behalf of your Organization in order to:

• Register and administer to your Platform and/or App account;
• Carry our obligations arising from any agreement entered into between Bringg and your Organization. Please note that such obligation includes full disclosure of any Personal Information collected and/or processed via the Platform and/or Apps to your Organization;
• Enable the overall operation of the Platform and/or Apps.
• In connection with your use of the Bringg Driver App, geolocation data shall be used to track the location of your mobile device to enable the operation of the App.
• In connection with your use of the Bringg Driver App, data relating to your use of the phone or other voice application on your mobile device while the App is open or running on that mobile device, shall be used to determine if such use is blocking data transmission or otherwise interfering with the functionality of the App.
• Personalize your experience on the Platform and/or Apps.
• Ensure that content on the Platform and/or Apps is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
• Personalize third party ads.
• Identify you when conducting customer service operations.
• Send you updates, notices, announcements, and additional information related to Bringg, the Platform and/or the Apps.
• Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes.
• Keep the Platform and Apps safe and secured and for prevention of fraud.
• Comply with our legal obligations and to in order to be able to protect our rights and legitimate interests.
• We will use Personal Information collected via cookies in order to enable the customer journey and as part of our legitimate interests in a safe and user-friendly presentation of our Platform and Apps.

Note to our Users in the EU:

In order for Bringg to process your Personal Information, as detailed herein, such processing must be justified by a “basis” for processing, which has been determined exclusively by your Organization. Please note that the processing may be justified on the basis that:

• the processing is based on your consent (i.e. where you provided your Organization with consent to a specific type of data processing purpose);
• the processing is necessary for your performance of a contract between you and your Organization;
• the processing is necessary to enable your Organization to comply with a legal obligation (e.g. disclosure of information to authorities); or
• the processing is in your Organization’s legitimate commercial interests, subject to your interests and fundamental rights.

If you have any questions or require any clarifications regarding the basis for processing your Personal Information, please refer to your Organization.

Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE PLATFORM AND/OR APP, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.

6. Sharing Personal Information with Third Parties

     6.1. Bringg respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, except as specifically instructed by your Organization or as detailed in this Privacy Policy.

     6.2. Please note: All information that Bringg shall collect from you and process through your use of the Platform and/or Apps is fully disclosed to your Organization which is the owner, and where applicable considered as the “controller”, of such information.

     6.3. We may share your information in the following cases:

Group Companies: the Personal Information you provide to us may be accessed by members of our group companies in order to fulfill the purposes detailed herein.
Bringg Personnel: Personal Information that we collect and process on behalf of your Organization may be transferred to or accessed by personnel of Bringg for the sole purpose of enabling the operation of the Platform and/or Apps and to carry our obligations arising from any agreement entered into between Bringg and your Organization. Please note that all Bringg personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processers that perform services on our behalf, including without limitation, companies that provide analysis, monitoring, and reports, route guidance and maps, messaging services and services which host the Platform and Apps. Please note that we collect, hold and manage your Personal Information through a third party’s cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 9 below.
In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy or any other agreement or terms of service between you and Bringg and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of Bringg, its Users or the general public; (e) to respond to claims that any content published on the Apps violates any right or endangers the safety of any third-party; and (f) when Bringg is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Bringg (while such acquired company or investor may be located in countries outside of your jurisdiction).

     6.4. For avoidance of doubt, Bringg may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of its Platform and/or Apps.

7. Your Rights

Bringg acknowledges that you have the right to access and change the Personal Information we collect and process, on behalf of your Organization, in our capacity as a “processor” of data. If you wish to access or to correct, amend, or delete Personal Information, please contact your Organization or use the appropriate functionality in the Platform and/or Apps. If your Organization requests that Bringg will remove Personal Information, Bringg will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.

Note to our Users in the EU:

We hereby inform you of the following rights (by virtue of EU law) with respect to the processing of your Personal Information:

Right to access: you may have the right to request a review of your Personal Information held by Bringg.
Right to rectification: if the Personal Information processed by Bringg is incorrect, incomplete or not processed in compliance with applicable law or this Privacy Policy, you may have the right to have your Personal Information rectified.
Right to erasure: under certain conditions, you may be entitled to require that Bringg will delete or “block” your Personal Information (e.g. if the continued processing of a specific data is not justified).
Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information from your Organization to another entity).
Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact your Organization or, if applicable, use the appropriate functionality available on the Platform and/or Apps.

8. Location of your Data

The information collected from you by Bringg, as detailed in this Privacy Policy, may be transferred to, and stored at, servers which may be located in countries outside of your jurisdiction and in a country that is not considered to offer an adequate level of protection under your local laws. It may also be processed by Bringg and its suppliers, service providers or partners’ staff operating outside your country.

Bringg is committed to protect your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps include putting in place data transfer agreements or ensuring our third-parties comply with Bringg’s data transfer protection measures.

Note to our Users in the EU:

If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.

In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:

• Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;
• Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;
• Transferring your Personal Information to organizing that are Privacy Shield Scheme certified, as approved by the European Commission.

BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE PLATFORM AND/OR APPS, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

9. Minors

The Platform and/or Apps are intended for Users over the age of sixteen (16). Therefore, Bringg does not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Platform and/or Apps.

10. Third Party Service Providers and Third Party Software

     10.1. While using the Platform and/or Apps we may be using third party service providers, which may collect, store and/or process your information, as detailed in this Privacy Policy.
     10.2. Note, that we may collect, hold and/or manage your Personal Information through Bringg’s authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) which may use your information solely in order to provide us with such requested services, and not for any other purposes.
     10.3. Such vendors may be located in countries that do not have the same data protection laws as your jurisdiction.
     10.4. Such third parties service providers include without limitation:

• Google Fabric, which privacy policy can be found at https://policies.google.com/privacy;
• Amazon AWS, which privacy policy can be found at https://aws.amazon.com/privacy/;
• Google Cloud, which privacy policy can be found at https://cloud.google.com/terms/;
• Microsoft Azure, which privacy policy can be found at https://privacy.microsoft.com/en-us/privacystatement;
• Mandrill, which privacy policy can be found at https://mailchimp.com/legal/privacy/;
• Google Maps, which privacy policy can be found at https://www.google.com/policies/privacy/;
• Twillio, which privacy policy can be found at https://www.twilio.com/legal/privacy; and
• Vonage/Nexmo, which privacy policy can be found at https://www.nexmo.com/privacy-policy.

Please read such third party service providers’ terms of use and privacy policies to understand their privacy practices.

11. Links to Third Party Websites

Certain links provided in the Site and/or Platform permit Users to leave our Platform and/or Apps and enter non-Bringg sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of Bringg and it is not responsible for the availability of such external sites or services and does not endorse and is not responsible or liable for any content advertising, products, services or other information on or available from such linked sites and services or any link contained in a linked site or service. Bringg reserves the right to terminate any link at any time. You further acknowledge and agree that Bringg shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resource. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

12. Cookies & Local Storage

     12.1. When you access or use the Platform via a web browser and/or the Apps, Bringg uses industry-standard technologies such as “cookies,” other tracking technologies, other local files and Flash (or similar technologies), which store certain information on the browser or hard drive of your computer and/or your mobile telephone device (“Local Storage”) and which will allow us to distinguish you from other users, enable automatic activation of certain features and improve your User experience and other capabilities.

     12.2. Some cookies used by the Platform and/or Apps are created per session, do not include any information about you, other than your session key and are removed as your session ends (usually after 24 hours). Other cookies remain saved to your device’s hard drive and/or your mobile telephone device and enable us to recognize your device in the event of a later visit to our website (persistent cookies). Persistent cookies allow us to make our Apps and Platform more user-friendly, effective and safe.

     12.3. It is easy to prohibit the Local Storage. Most devices and browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option in Flash you should use the settings option of Flash according to the specific instructions provided by the technology provider. However, if you block or erase cookies, or change the settings of Flash, your experience of the Apps and Platform may be limited. Please note that unless you block the acceptance of cookies, the Platform and App will utilize cookies upon your log-on to the Platform and/or App all unless it is required by applicable law to provide a separate consent to use such cookies, and in which case we will use such cookies only after we receive your separate consent to such use and subject to your right to withdraw such consent at any time)

12.4. Cookies and other Local Storage help Bringg to personalize the Platform and the Apps, and to:

• track clicks, and online activity to estimate usage pattern and perform other analytics;
• gather information about your approximate geo-location to provide localized content;
• store information about your preferences and the device or browser you are using, and thereby customize and personalize the Platform and/or Apps;
• personalize ads or other services;
• improve the Platform and Apps; and
• prevent fraud and/or abuse of our services.

13. Security

     13.1. We take appropriate measures to maintain the security and integrity of our Platform and/or Apps and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.

     13.2. Your Personal Information is hosted on Amazon AWS, Google Cloud and Microsoft Azure servers which provide advanced strict security standards (both physical and logical).

     13.3. Some of the Security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, restriction of access to your Personal Information to individuals who need access to it in order to process it on Bringg’s behalf and implementation of a secure permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms.
Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.

     13.4. Bringg will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.

     13.5. TO THE EXTENT THAT BRINGG IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, BRINGG SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.

14. Data Retention

Bringg will retain the Personal Information that your Organization has instructed us to process for it for as long as needed to provide Bringg’s services to your Organization, and in accordance with the contractual terms stipulated between Bringg and your Organization. Your Organization can at any time instruct us to delete such Personal Information.

In addition, Bringg will retain Personal Information as necessary to comply with its legal obligations, resolve disputes, and in accordance with Bringg’s agreements with your Organization, all subject to applicable privacy laws.

15. Changes to the Platform Privacy Policy

Bringg reserves the right to change this policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Platform and/or Apps or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Platform and/or Apps or sent to you via e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Platform and/or Apps on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

16. Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, please contact you Organization or you can send us an email to the following address: privacy@bringg.com and we will make an effort to reply within a reasonable timeframe.