Privacy policy

A.I Conversation Systems Ltd., Cocohub Inc., Cocohub Ltd. and their Affiliates (jointly “Cocohub”, “we”, and “us”) place great importance on the protection of your privacy. This Privacy Policy (“Privacy Policy”) details how Cocohub processes Personal Data in its capacity as a data controller. It also details your rights and choices in respect of use, access, amendment and deletion of your Personal Data.

DEFINITIONS

All capitalized terms used in this Policy and not defined herein, will have the same meaning ascribed thereto in Cocohub’s terms of use located at: https://about.cocohub.ai/terms-of-use (“TOU”).

  1. PERSONAL DATA COVERED UNDER THIS PRIVACY POLICY

    This Policy applies to processing of Personal Data collected by Cocohub in the process of:

    • Receiving communications from Cocohub.
    • Visiting our Website.
    • The use of our Services through our Platform or any third party applications, by our Customers and our Customer’s Users.

  2. TYPES OF PERSONAL DATA COLLECTED BY US

    A) Personal Data collected from data subjects (“Collected Data”)

    1. Sign-up, Account information and Billing Information.

      When a Customer or a Customer User, signs-up to or uses any of our Services, Cocohub may collect its (i) contact information including name, e-mail address, phone number, mailing address, IP address, geographic location; (ii) billing information, including credit card data and billing address; and (iii) unique identifiers, such as username and password.

    2. Customer Data

      When you use our Services, we process the Customer Data in accordance with and subject to our Data Processing Addendum [https://about.cocohub.ai/data-processing-addendum]. We may conduct analytics on such data to (i) evaluate your needs to determine or suggest our Services; (ii) send you information concerning our Services; (iii) provide response to customer requests and questions; and (iv) for products and Services improvement purposes.

    3. Usage Data

      We collect and record audio, video, text, clicks, scrolls, conversion and drop-off on Services and Websites to render the Services in real-time. Subject to this Policy, we will use such data and Customer Data, including without limitation, to (i) evaluate your needs to determine or suggest our Services; (ii) send you information concerning our Services; (iii) provide response to customer requests and questions; and (iv) for products and Services improvement purposes, including to train our Services to better recognize human speech, interaction, and gestures.

    4. Cookies and equivalent technologies

      Cocohub and our third party partners use cookies and other tracking technologies to track movement around the Website, usage of the Services, and gather demographic information. We may generate reports based on such technologies on an individual or an aggregated basis. You can control the use of cookies by using your browser capabilities. Please note that choosing to disable cookies, may limit your ability to use certain functions or features of the Services or our Website.
      Additional information collected by our Website and Services includes IP addresses, browser type, internet service provider, referring/exit pages, the content viewed on our Websites or Services, date/time stamp, and operating system. Such data may be linked to other data collected in your respect.
      Additional information concerning our use of Cookies and other tracking technologies is available in our Cookies Policy [https://about.cocohub.ai/cookie-policy].

    5. Mobile Devices

      When you use our Services through your mobile device, we will collect information on the type of your device, its operating system, and its identifier.
      Cocohub may use mobile analytics services to better analyze the functionality of our Services and Websites on mobile devices. Such services may collect certain information such as frequency of use, aggregated usage, performance data, and the events occurring during use of our Services.

    6. Sign-in services

      It is possible to log in to our Services or Websites using sign-in services such as Google, Facebook and similar services. These services will authenticate the Customer or Customer User’s identity and allow the sharing of certain Personal Data with Cocohub such as your name and e-mail address and are regulated under the privacy policy of their applicable provider. Services like Google, Facebook, Twitter and LinkedIn provide the option of posting information regarding your use of our Services and Websites to your applicable profile page and share information with other users.

    7. Third party cookies and Social Media

      Our Websites may include social media features, such as the Facebook “Share” or “Like” buttons or other third party interactive applications. Where you interact with these features, they may collect your IP address, the pages visited on our Services or Websites, and may use cookies to enable certain features. Such social media features may be hosted by third parties or hosted directly on our Services or Websites. Interactions with such social media features will be regulated under the privacy policy of their applicable provider. Additional information is available in our Cookies Policy [https://about.cocohub.ai/cookie-policy].

    B) Information collected from third parties

    We may receive personal information from third parties like social media and other databases subject to such third parties having obtained your consent or are otherwise legally permitted or required to disclose such information to us.
    Types of information obtained from third parties may include names, e-mail addresses, locations and telephone numbers and will be used by us for sales and marketing purposes, to maintain and improve our customer support and the accuracy of our records.

  3. OUR LEGAL BASIS FOR PERSONAL DATA PROCESSING

    Personal Data is collected and processed by us for the following purposes and based upon the following basis:

    • Provision of the Services, administering Customer’s or Customer User’s accounts, collecting fees and moneys due to Us, responding to service requests or questions, and evaluating your needs to determine or suggest our Services – Consent, Performance of Contract and Legitimate Interest.
    • Prevention of and response to any misuse of the Services or any violations of applicable laws or our TOU – Legitimate interest.
    • Performance of analytics, training of our algorithms, improving, developing, operating and supporting the Services and their availability, development of new products and services and provision of customized features and content – Consent and Legitimate interest.
    • Sending promotional and marketing communications – Consent. If you do not wish to receive such communications, you can opt out by following the instructions set forth below.
    • Responding to lawful requests by competent authorities, including as required under any security or law enforcement requirements and disclosure is necessary to protect our rights, comply with judicial proceedings, court orders or other legal process – Legal Requirement and Legitimate Interest.

  4. SHARING PERSONAL DATA WITH THIRD PARTIES

    Personal Data is processed by Us and any third parties that we use, in the United States, Israel and the European Economic Area (“EEA”) and may be processed in other countries through third parties engaged by us.

    Personal Data may be shared by us as follows:

    • Third parties assisting Cocohub in provision of the Services (“Sub-Processors” listed in our Processors List [https://about.cocohub.ai/data-processors-list]). Sub-Processors are given access to Personal Data only as reasonably required for the provision of the Services;
    • Third-party payment processors who process credit cards and other payment information for Cocohub;
    • Third parties assisting Cocohub in our business activities, which may include marketing, advertising, support, technical operations, on boarding and maintaining and improving Services;
    • Third parties providing services, such as analytics, anti-spamming ,anti-phishing;
    • Third-party social media networks, advertising networks and websites;
    • Third parties with which we may be involved in business transactions such as mergers, reorganizations, acquisitions or other fundamental corporate changes, including at the due diligence stage.

    All such transfers are covered by adequate legal arrangements which impose confidentiality obligations and appropriate safeguards for the protection of Personal Data in accordance with this Privacy Policy.

  5. INTERNATIONAL DATA TRANSFERS

    Any transfers of Personal Data under this Privacy Policy from the European Union, the European Economic Area and/or their member states, Switzerland and the United Kingdom to countries which do not ensure an adequate level of data protection within the meaning of Data Protection Laws and Regulations of the foregoing territories, is to be made based on the Standard Contractual Clauses set forth in our DPA [https://about.cocohub.ai/data-processing-addendum]. Cocohub undertakes to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and follow any advice handed down by such authorities regarding Personal Data transferred from the EU and Switzerland.

  6. SECURITY MEASURES USED BY US

    Our systems employ adequate technical and organizational measures for protection of Personal Data collected and processed by us. Such measures are intended to provide adequate level of security in respect of the risks involved in our processing of Personal Data.
    Please note that information security risks are always evolving and cannot be completely avoided. The technical and organizational Data Protection measures employed by us are periodically examined within the scope of internal and external audits. For questions concerning the security of your Personal Data, please contact us.

  7. ADDITIONAL INFORMATION FOR EEA AND SWISS RESIDENTS

    A) Collected Data

    Individual residents of EEA or Switzerland, have the following data protection rights:

    • You may access, correct, update or request deletion of your Personal Data, any time, by contacting us.
    • You may object to processing of your Personal Data, ask to restrict processing of your Personal Data or request portability of your Personal Data, any time, by contacting us.
    • You may opt-out of marketing communications sent by us at any time. You may exercise such right by clicking the applicable “unsubscribe” link in the communications sent by us. For opting out of other forms of communications (such as postal or telemarketing), please contact us.
    • You may withdraw your consent for collection and processing of your Personal Data by us at any time.
    • You may file a complaint to the competent data protection authority in respect of our collection and use of your Personal Data.

    If you wish access, correct, update, modify or delete your Personal Data, please contact our DPO at support@cocohub.ai. We will use our best efforts to respond to all requests within a reasonable timeframe in accordance with applicable data protection laws.

    B) Customer Data

    Cocohub processes Customer Data on behalf of its Customers and has no direct relationship with the Customer Users whose Personal Data it processes as Customer Data. If you wish to access, or wish to correct, update, modify or delete Personal Data which is part of the Customer Data, you should request to exercise such rights directly from our applicable Customer which is deemed controller of such Customer Data. Customer Data removal requests will be processes by us within a reasonable timeframe in accordance with applicable data protection laws.
    Customers of our Services who wish to raise a request on behalf of their Users in connection with Customer Data, may do so by contacting us at support@cocohub.ai.

  8. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

    ‘Consumer’ as defined under the California Consumer Privacy Act of 2018 (“CCPA”) is entitled to the rights set forth below:

    a. Right to request information concerning:

    • Categories of Personal Data collected about you.
    • Specific pieces of Personal Data collected about you.
    • Categories of sources of collection of Personal Data.
    • Business or commercial purposes for Personal Data collection.
    • Categories of third parties with whom Personal Data is shared.

    b. Right to request deletion of Personal Data collected about you.

    If you wish to exercise any of the foregoing rights in respect of ‘personal information’ as defined in CCPA, please contact us at support@cocohub.ai. We will use our best efforts to respond to requests within a reasonable timeframe in accordance with applicable data protection laws. By contacting us, you agree to receive communications for the purpose of validating your identity and such other information reasonably required to process your request.

    Please see the information set forth above in respect of categories of ‘personal information’ collected and categories of third parties with whom such ‘personal information’ is shared. For the avoidance of doubt it is hereby clarified that Cocohub does not sell ‘personal information’.

  9. OPTING OUT

    If you no longer wish to receive communications from us, you may click on the “unsubscribe” link located on the bottom of our communications or you contact us at support@cocohub.ai.

  10. OTHER COMMUNICATIONS

    Cocohub may send you communications on occasions when we deem it operationally necessary to do so, for example in cases of Services suspension for maintenance. Opting out of such communications (which are not promotional) is not possible. Customers who do not wish to receive such communications, will need to delete their Customer Account.

  11. PERSONAL DATA RETENTION

    Personal Data which forms part of the Customer Data is retained and expunged in accordance with our TOU.
    If you us to stop using and retaining your Collected Data, please contact us.
    Notwithstanding the aforementioned, Collected Data and Customer Data will be retained by us for the periods required to comply with our legal obligations, for litigation purposes, for maintaining precise financial records and enforce our rights under valid contracts.

  12. . LINKS TO THIRD PARTY SITES

    The Services and Website may contain links to third party websites that are not controlled by us. Cocohub is not responsible for the privacy practices of such third-party websites. You are highly encouraged to read the privacy policies of each such third website prior to allowing collection of your Personal Data.

  13. CHILDREN’S PERSONAL DATA

    We do not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please refrain from submitting any Personal Data through Cocohub’s Websites or Services. Parents and legal guardians are highly encouraged to monitor their children’s Internet practices and prevent the provision of their Personal Data through our Services or Websites without their parents and legal guardians` permission. If you are aware that any Personal Data of a child under the age of 16 has been provided to us without permission of his parents and legal guardians, please contact us immediately and we will delete such information from our databases.

  14. AMENDMENTS

    Amendments to our Privacy Policy will be posted to our Website and will be effective when posted. You should frequently visit our Privacy Policy to keep fully informed of any changes. Your continued use of our Websites or Services following the posting of any amendment to this Privacy Policy shall be deemed as acceptance of the Amended Privacy. Any amended Privacy Policy will not apply to Customers who terminated their account within 10 days of any amendment posting as aforementioned.

  15. CONTACT

    For any questions concerning this Privacy Policy or other privacy related matters, please contact us at support@cocohub.ai or via post at Ha’hasmonaim 100, Tel Aviv, Israel, 6713317, att: Data Protection Officer.

  16. GOVERNING LAW; JURISDICTION.

    This Privacy Policy will be governed by and construed according to the laws of the State of Israel, without reference to its conflict of laws provisions. The parties agree to submit to the personal and exclusive jurisdiction of the courts in Tel Aviv, Israel.