Privacy Policy

Kndy’s Technologies Ltd. (“We”, “Us” or “Kndy’s”) welcomes Users of the Platform, End Users of User’s Platform or Visitor to Our Platform, (“You”) to learn and become informed on how We invest efforts to ensure that your personal data is kept safe and used properly.

This Privacy Policy describes how, regarding Kndy’s Platform and Services as defined below, we collect, store, use and disclose the following types of personal data:

(i)             End User Data: personal data that we, process and manage on behalf of our Users, submitted to the Kndy’s cloud-based Marketplace platform-as-a-service or mobile applications and related products, integrations, add-ons and extensions services managed and operated by Kndy’s (collectively, the “Platform”). We process such End User Data on behalf and under the instruction of the respective User in our capacity as a “data processor” in accordance with Our specific data processing arrangements with them. Accordingly, this Privacy Policy – which describes Our independent privacy and data processing practices as a “data controller” – does not apply to the processing of End User Data.

(ii)           User data personal data relating to individuals or corporations who register or are already registered to the Platform and use it either independently or on behalf of our Users (the: “User”), to document, collect and act in any manner under our Platform;

(iii)         Interim Data: personal data relating to visitors of our Platform, website, app, business customers, partners, and any prospective customer, partner (“Visitors”), who visits or otherwise interacts with Our website, online ads and content, emails or other communications under Our control (herein “Services”).

If you are a User, End User or Visitor, please read this Privacy Policy carefully and make sure that you fully understand and agree to it. This Privacy Policy, together with Our Terms of Service form a binding agreement between You and Us.

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 (defined below), please refrain from accessing, using or registering to our Platform or engaging Our Services.

Data Collection and Processing[d1] 

We collect and generate the following types of personal data:

(i)    Contact and Account information Name, email, phone number, login credentials, contractual and billing details, and any other information submitted by Users or otherwise available to Ys when Users signup or login to the Platform (either directly or through their social media or organizational Single-Sign-On account), when engaging our Platform including when creating an Account.

We collect this information directly from Users, or from other sources and third parties.

(ii)  Usage and device information Connectivity, technical and usage data, such as IP addresses and approximate general locations derived from such IP addresses, device and application data (like type, operating system, mobile device or app id, browser version, location and language settings used); system logs of actions and events attributed to those IP addresses, devices and applications; the relevant cookies and pixels installed or utilized on your device; and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of Prospects and Users in connection with our Platfrom.

We collect and generate this information automatically, including through the use of analytics and system monitoring tools (including cookies and pixels) – which collect data such as: how often Prospects visit or use the Sites, which pages they visit and when, which website, ad or email message brought them there, how Users interact with and use the Platform and its various features, and technical data concerning the performance, functionality and stability of the Platform.

(iii)                  Communications  Personal data contained in any forms and inquiries that you may submit to Us, including support requests, interactions through social media channels and instant messaging apps, registrations to events that we host, organize or sponsor, and participation in our online and offline communities and activities); surveys, feedback and testimonials received; expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement; and sensory information including phone call and video conference recordings (e.g., with our customer service), as well as written correspondences, screen recordings, screenshots, documentation and related information that may be automatically recorded, tracked, transcribed and analyzed, for purposes including analytics, quality control and improvements, training, and record-keeping purposes.

1. Data Uses & Lawful Bases & Consent

We use personal data as necessary for the performance of our Platform (“Contractual Performance”); to comply with our legal and contractual obligations (“Legal Obligations”); and to support our legitimate interests in maintaining and improving our Platform, e.g. in understanding how our Platform is 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 Platform to You and others; providing customer services and technical support; and protecting and securing our Users, ourselves and our Platform (“Legitimate Interests”).

Your engagement with the Platform, including engaging Our website, the App is deemed as Your express and inform consent to the collection and/or processing (as applicable) of your personal data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at jojo@appolo.cloud .

Specifically, we use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

(i)    Customer and User personal data:

To facilitate, operate, enhance, and provide our Platform and Services; (Performance of Contract; Legitimate Interests);

To provide You with assistance and support, to test and monitor the Platform, diagnose or fix technical issues, and to allow You optimal use of Our Platform (Performance of Contract; Legitimate Interests);

To invoice and process payments (Performance of Contract; Legitimate Interests); and

To personalize Our Platform, including by recognizing an individual and remembering their information when they return to the Platform, and to provide further localization and personalization capabilities (Performance of Contract; Legitimate Interests);

To gain a better understanding on how You evaluate, use, and interact with the Platform, to utilize such information to continuously improve our Platform, the overall performance, user-experience and value generated therefrom. We collect such information automatically through Your us of the Platform (Legitimate Interests);

To create aggregated, statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which We or others may use to provide and improve our Platform, or for any other business purpose such as business intelligence (Legitimate Interests);

To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Platform more effectively (Legitimate Interests; Consent);

To contact You general or personalized Platform-related messages, as well as promotional messages that may be of specific interest to them (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 (Performance of Contact; Legitimate Interests; Legal Obligation);

To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences, including through partnerships with local distributors, resellers, business partners and providers of professional services related to our Services (some are described herein);

To facilitate, sponsor and offer certain events, webinars, contests and promotions (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); and

For any other lawful purpose, or other purpose that you consent to in connection with Our Platform. (Legal Obligation; Consent).

1. Data Location & Retention

(i)   Data Location: Your personal data may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the the EU, and other jurisdictions, as reasonably necessary for the proper performance and delivery of our Platform, or as may be required by law. Kndy’s main hub is located in Israel, and operated by our Israeli entities. Israel is considered by various jurisdictions, including the EU, to be offering an adequate level of protection with regards to data transfer requirements.

(ii)  Data Retention: We will retain Your personal data for as long as it is reasonably necessary for Us to maintain and expand our engagements and provide you with the Platform; 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 in order to have proof and evidence concerning our engagements, should any legal issues arise following Your use), all in accordance with our contractual terms and discretion.

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.

1. Data Disclosure

(i)   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) and where such disclosure is necessary to comply with applicable laws and regulations. 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 act regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services.

(ii)  Service Providers: We contract selected third-parties to perform services complementary to our own such as: hosting and server co-location services, communications and content delivery networks (CDNs), billing and payment processing services, data and cyber security services, fraud detection and prevention services, web and mobile analytics, e-mail, text messages and web/mobile notification distribution, monitoring and analytics services, data optimization and marketing services, social and advertising networks, content providers, support and customer relation management systems, call and session recording services, and our legal, financial and compliance advisors (collectively, “Service Providers“).

These Service Providers may have access to Your personal data, depending on each of their specific services provided to Us, and may only use it for such limited purposes as determined in our agreements with them. Should you decide to directly engage with any of Our Service Providers, whether thorough Our Platform or independently from it, then such engagement is beyond the scope of Our Terms of Service and Privacy Policy and not covered by them, but rather by Our Service Provider’s terms and policies.

Our Service Providers shall be deemed as ‘data processors’ in circumstances where We assume the role of ‘data controller’; and where We acts as the ‘data processor’ for Users, the Service Provider shall be deemed our ‘sub-processor’.

(iii)  Third Party Websites and Services: Our Services may also include links to third-party websites, and integrations with third party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services.

(iv)Legitimate Business Purpose: We may also transfer your data for our legitimate business reasons in the following events: (1) Corporate: Any of our subsidiaries, parent or affiliate entities; in the event that we are acquired, or substantially all of Our assets are purchased, or We otherwise merge with a third party, form part of a partnership or joint venture or any similar transactions or engagements. (2) commercial engagements: selected business and channel partners, resellers, vendors and providers of professional services, which are related to our Services and Platform.

(v)  Feedback or Recommendations: If You submit a public review or feedback, We may be free to store and present your review publicly, on through Our Services and Platform.

(vi)Third Party Integrations and API’s: You may choose to integrate your Account on the Platform with a third-party service (provided that we allow such integration). The provider of this integrated third-party Services may receive certain relevant data about or from your Account on the Platform, or share certain relevant data from the Account on the third-party provider’s Services with our Platform, depending on the nature and purpose of such integration.

1. Cookies and Tracking Technologies

Cookies (by which We collectively mean: Cookies, anonymous identifiers, pixels container tags and other technologies) are packets of information sent to Your web browser or device and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and called “Persistent Cookies”. We use both types.

We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

Utilizing Cookies is an acceptable practice and allows Us to provide and monitor the use of our Services and Platform, to ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Certain cookies and other technologies serve to recall personal data, such as an IP address. These are non-exhaustive examples. 

Most common browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using certain parts of features of the Platform.

We also use analytics tools to help us understand your behavior on our Platform, including by tracking page content, and click/touch, movements, scrolls and keystroke activities.

For more information, please review our Cookie Policy.

1. Communications

(i)   Service Communications: We may send you notifications (through any of the means available to us, including by email, SMS and mobile notifications) of changes or updates to our Platform, billing issues, service changes, etc. Please note that you will not be able to opt-out of receiving service communications which are integral to the operation of our Platform and your use thereof.

(ii)  Promotional Communications: By agreeing to this Privacy Policy you also accept promotional communications from us such as, but no limited to, our newsletter. We may also notify you about new features, additional offerings, better ways to use the Platform, events and 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. phone, SMS, mobile notifications or e-mail), through the Platform, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may unsubscribe or otherwise opt-out of promotional communications you receive by the means we make available.

1. Information Security

We and our Service Providers implement systems, applications, and procedures to secure your personal data, and to reduce the risks of theft, damage, loss of data, or unauthorized access or use of personal data. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Platform and Services will be immune from any wrongdoings, malfunctions, data breach, unlawful interceptions or access, or other kinds of abuse and misuse.

1. Data Subject Rights

If you wish to exercise your rights under any applicable law, such as request access to, and rectification or erasure of your personal data held with Us, or to restrict or object to such personal data’s processing, or to port such personal data – please contact us via the contact information in this Privacy Policy.

Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure of personal data related to others and to ask you to provide further information to better understand the nature and scope of the data to which your request pertains. Such additional information will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request). We will follow any applicable statutory procedure with regards to exercising Your applicable rights in this respect.

In cases regarding requests from End Users in Our capacity as Data Processors, note that the User with which You contracted exclusively determines how such data is processed, as well as if and how your request should be handled – so we advise that you submit your request directly to them.

We respect Your rights and naturally, You are  required to cooperation with Us to properly handle and process requests. If You fail, for some reason, to cooperate with Us we will not be able to process or handle Your request.

We may redact from the data which we will make available to you, any personal data or confidential information related to Us or others.

1. Data Controller/Processor

It is customary to 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 the Platform, to the extent that such laws and regulations apply.

We are the “data controller” of personal data pertaining to Our Users, vendors and certain visitors, and We assume the responsibilities of a 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”.

We are the “data processor” of registration and deregistration data pertaining to Or Users’ End Users (solely to the extent that such data is shared by Our User during their Use of the Platform). In such instances, Our Users are deemed the “data controller” of such data, and We will process such data on their, as its “data processor”, in accordance with its reasonable instructions, subject to our Terms and Conditions, this Privacy Policy, and the commercial and data processing agreements executed between Us and them (as applicable). In such instances, Our Service Providers shall then act as designated sub-processors. Our User’s will be responsible for meeting any legal requirements applicable to data controllers (such as obtaining consent or establishing other legal basis for processing).

10. Additional Notices

(i)   Updates and Amendments: We may update, change or amend this Privacy Policy or any part thereof in our sole discretion, from time to time by posting an amended version on our Platform. The amended version will be effective as of the date it is published. After posting the new version of this Privacy Policy and Your continued use of Our Services, all amendments shall be deemed accepted by you.

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

(iii)      Our Services are not designed to attract children under the age of 18: 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 18 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

(iv)Data Protection Officer: We appointed Sekler Levi Law Firm as our Data Protection Officer (DPO). If you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Kndy’s please contact Us.

(v)  Questions, concerns, or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact us at: jojo@appolo.cloud

 [d1]Please Review and ensure all data collected is mentioned