Privacy Policy
A Legal Disclaimer
Curated Ltd. (“Curated”, the “Company”, “us”, “our” or “we”) respect the privacy of our website's and Platform's users (“User(s)” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our website at [please insert a link] and its subdomains (the “Site”) and/or our Platform and Services (as such terms are defined in our Terms of Use). Please read the following carefully to understand Curated’s views and practices regarding your personal information and how Curated will treat it.
Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at [please insert a link], into which this Privacy Policy is incorporated by reference.
Important note for Platform's Users: The Platform is provided to Users solely in connection with services that we provided to the User’s employer or other business that authorized the User to access and use the Platform (collectively, “your Organization”), under a separate agreement executed between your Organization and Curated. [Please note that your Organization is an independent data controller of the personal data that may be collected or otherwise processed in connection with your use of the Platform. As such, your Organization will receive access to said personal data, as described in this Privacy Policy, and may use it for its purposes, and in accordance with its own independent practices. Please confirm] BY DOWNLOADING, ACCESSING AND/OR USING THE PLATFORM, YOU ACKNOWLEDGE THAT THE PERSONAL INFORMATION COLLECTED, USED, PRODUCED OR OTHERWISE PROCESSED IN CONNECTION WITH YOUR USE OF THE PLATFORM, MAY BE MONITORED AND BECOME AVAILABLE TO YOUR ORGANIZATION, AND MAY BE USED BY YOU ORGANIZATION, AT ITS DISCRETION. IF YOU DO NOT AGREE TO ANY TERM PROVIDED HEREIN, PLEASE CONTACT YOUR ORGANIZATION AND CEASE ANY ACCESS OR USE OF THE PLATFORM
1. Who we are [Please Complete]
In this policy, references to Curated, or to the “Company”, “we”, “ours” or “us” are to Curated Ltd., having its principal office at [please add Company's full address]. 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 [please add email address].
2. Your Consent
This Privacy Policy (“Privacy Policy”) details how your Personal Information collected via the Site and/or the Services and/or the Platform is used and processed by Curated.
BY REGISTERING, ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR THE SERVICES AND/OR THE PLATFORM, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SITE AND/OR THE SERVICES AND/OR THE PLATFORM AND YOU SHOULD NOT PROVIDE US WITH ANY PERSONAL INFORMATION. FOR THE AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.
3. Which information may we collect about Users? [Please review this section and advise whether this is accurate]
We may collect two types of data and information from our Users:
3.1. Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the Site and/or the Platform (“Non-Personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information.
You may access and browse the Site and/or the Services and/or the Platform without disclosing personal information, although, like most websites and platforms, we passively collect certain Non-Personal Information from your devices, including: (i) technical 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.; and (ii) behavioral information which may include the User’s click-stream on the Site/Platform, the activities of the User on the Site/Platform and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use [third-party service providers, such as Google Analytics, to obtain detailed analytics on the device and the User's behavior on the Site and Platform. Please confirm] Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain tracking technologies, such as cookies, as further detailed below.
3.2. Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:
3.2.1. Personal Information which is provided voluntarily: [Please review this entire section carefully and confirm/amend as necessary]
● Communications with Curated: Personal Information you provide us as part of any communications with Curated, by any means, including by contacting us via the Site, our chatbot, email, approaching our customer services, or during sales calls or through our social network pages (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences). Please note that we may record calls for quality assurance purposes and in order to improve our services.
● Contact Details: Personal Information is collected from the details the Users provide in the "ContactUs" form available on the Site. Such Personal Information includes your full name and email address. You may provide via the contact form any text you wish to insert into the “message” box. Additional information may be requested via the contact form in the future.
● Book a Demo: you may request a demo of our Services by providing us your full name, business email address, phone number, job title and company name. We may request additional information to complete your application.
● Our newsletter and other commercial materials: you may voluntarily provide us with your contact details in order to subscribe to our newsletter and to receive commercial materials from Curated and our partners.
● Account: Personal Information is collected from the details the Users provide as part of the registration to the Platform and creating, modifying or logging into their Account. Such Personal Information may include your name, password, company name and e-mail address, and any other information which you may voluntarily provide to us.
● User Data: When you use the Platform, you may upload, store, or share User Data that contains Personal Information about yourself or others. You are solely responsible for ensuring that you have the right and authority to upload, store, or share any User Data that contains Personal Information, and that you have obtained all necessary consents, permissions, and notices from any third parties whose personal information is included in your User Data.
● Information derived from your use of the Platform and/or Site: when you use the Platform and/or our Site, we are aware of you actions and interactions within our Services and may retain such information.
3.2.2. Personal Information collected via technology: [Please confirm]
● Geolocation data: while using the Site and/or Platform, we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes. Please note that we may also analyze your IP address and other similar data, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse to our Siteand/or Platform, for the purpose of locating prospects and in order to analyze our Site's traffic.
● Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 3.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
● Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or other unique identifiers for security purposes, analytics and in order to provide you with targeted advertising of our products and services.
3.2.3. Information from other sources:
● Data Provided by your Organization: Your Organization may share with us certain personal data, as necessary to provide you access to the Platform. This data may include without limitation: employee name, business email address and employee ID number. 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. [please confirm]
Please note:
● We may cross-reference your Personal Information with other Personal Information we may have about you. 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 Siteand Platform and for purposes of security and fraud prevention. We may also use cookies to gather information regarding your use of the Site and Platform and the information for which you searched and accessed.
4. How do we collect information about our Users?
There are a few main methods that we use in order to collect information:
4.1. We collect information through your entry, connection, access and/or use of the Site and/or the Services and/or the Platform. In other words, when you access or use the Site, we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site or Platform, we gather your Technical and Behavioral Information.
4.2. We collect information which you provide us voluntarily. For example, we collect Personal Informationwhen you contact us via the Site.
4.3. We collect information from other sources. For example, when you use the Platform, we collect Personal Information from your Organization. [please confirm]
We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.
5. What are the purposes of the collection and processing of information? [Please confirm]
5.1. Non-personal Information is processed in order to:
● Enhance the User’s experience on the Site and/or the Services and/or the Platform;
● Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and
● Keep the Site and/or the Services and/or the Platform safe and secured against fraudulent and criminal activity.
5.2. Personal Information is processed in order to: [Please confirm]
● To provide the Services and to enable the operation and constant improvement of the Site and/or the Platform;
● Customizing and enhancing the User's experience on the Site and/or the Services and/or the Platform;
● Send push notifications to Users. Users of the Platform can deactivate push notification by changing their settings within our Platform or by using their web browser/device’s settings; [please confirm]
● Verify the User's identity when they sign into the Platform;
● Be able to contact Users for the purpose of providing them with technical assistance and support;
● Determine the User’s geo-location to safeguard the Site and/or the Services and/or the Platform;
● Register your interest in our products and services;
● Contact you by telephone and/or by email with further information relating to our products or services which you enquired about via the Site;
● Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone or through web-browser notification. You have the right to opt-out of marketing messages at any time by following the instructions in such messages or by contacting us at: [Please Complete]. For email marketing to an individual subscriber (that is, a non-corporate email address) with whom we have not previously engaged as a client, we need your consent to send you unsolicited email marketing;
● Display ads and send you offers. We may also use your Personal Information in delivering third party advertisements to you. This may include "targeted ads" based upon your interactions with our Site and/or Platform; [please confirm]
● Personalize your experience on the Site and/or the Services and/or the Platform;
● Ensure that content on the Site and/or the Services and/or the Platform is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
● Conduct internal operations, such as: troubleshooting, data analysis, testing, research, and statistical analysis;
● Keep the Site and/or the Services and/or the Platform safe and secured against fraudulent and criminal activity;
● Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests;
● To conduct internal research;
● Maintain our data processing records and general administrative purposes; and
6. Cookies
When you access or use the Site and/or Platform, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, "Cookies"), which may enable us, amongst others, to recognize your device from those of other Users of the Site and/or Platform, to improve the Site's and the Platform's performance, to deliver a better and more personalized service according to our Users' individual interests and the device or browser used, to track Users' use of the Site and/or Platform, to gather information about the Users' approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Site and Platform, [and to serve targeted advertisements – please advise whether relevant].
Cookies may locally store certain Technical and Behavioral information and other Personal Information on your device and we and/or our authorized third party service providers may access such information for the purposes detailed under this Privacy Policy. We and/or our authorized third party service providers may use both session Cookies (which expire once you close the web-browser) and persistent Cookies (which stay on the User’s device until they delete them).
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 on your device. However, if you block or erase Cookies, your experience of the Site and/or Platform may be limited.
For detailed instructions regarding the blocking of Cookies, please refer to your browser's 'help', 'tool' or 'edit' sections or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.
[It is possible to opt-out of having your browsing activity within the Site recorded by performance cookies. Please note that we may use Google Analytics as our service provider in order to track Users' activities on the Site, including by use such services' persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout. – please advise whether relevant]
[You can opt out of receiving interest-based advertising on your device by visiting the following sites: www.aboutads.info/choices/, www.networkadvertising.org/choices/, and preferences-mgr.truste.com/. If you wish to opt out of receiving interest-based advertising on your mobile device, please see the advertising preferences information on support.apple.com for iOS devices or support.google.com for Android devices [please advise if relevant]
7. Sharing Personal Information with Third Parties
7.1. Curated respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy. In addition to using the information collected by us for the purposes described under Section 5 above, we may also share your information in the following cases:
● Curated Personnel and Affiliates: Personal Information that we collect and process may be transferred to or accessed by personnel of Curated and its affiliates for the sole purpose of enabling the operation of the Site and/or the Platform and to contact you (as detailed in Section 5 above). Please note that all Curated personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
● You Organization: All information that Curated shall collect from you and process through your use of the Platform is fully disclosed to your Organization which is an independent controller of such information, and may use your Personal Information for its own independent purposes. [Please confirm]
● Service Providers: Note, that we collect, hold and/or manage Personal Information through Curated'sauthorized third parties' vendors of certain products or services (such as, cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction. For more information regarding our Service Providers, please refer to Section 11 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 Curated, 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 Curated, its Users or the general public; and (e) when Curated is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Curated (while such acquired company or investor may be located in countries outside of your jurisdiction); (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; or (g) pursuant to your explicit approval prior to the disclosure.
7.2. For avoidance of doubt, Curated 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 our Site and/or the Services and/or the Platform.
8. Your Rights
Curated acknowledges that under circumstances you may have the right to access and to request an amendment or deletion of the Personal Information we collect and process about you. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: [please insert email address] and we will enable you to fulfill such rights, to the extent it is required under applicable laws.
9. Location of Your Data
We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. Any transfer of data will be in accordance with the safeguards permitted under applicable privacy laws. BY SUBMITTING YOUR PERSONAL INFORMATION TO CURATED, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.
10. Minors
The Site and/or the Services and/or the Platform are intended for Users over the age of eighteen (18). Therefore, Curated does not intend and does not knowingly directly collect any Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage to verify that minors under the age of eighteen (18) are not using the Site and/or the Services and/or the Platform.
11. Third Party Service Providers
While using the Site and/or the Services and/or the Platform, we may be using third party service providers, who may collect, store and/or process your information, as detailed in this Privacy Policy. Please read such third party service providers' terms of use and privacy policies to understand their privacy practices. Note, that we collect, hold and/or manage your Personal Information through Curated’s authorized third party vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction. Such third parties service providers may include without limitation the following categories of service providers:
• Cloud Services, such as Amazon AWS, which privacy policy can be found at: https://aws.amazon.com/privacy/.
• Analytics Services, such as Google Analytics, which privacy policy can be found at: https://policies.google.com/privacy?hl=en.
• Generative AI technologies, such as […]
• Please list any additional third party services providers who process or otherwise access personal data of users, such as Facebook, marketing services, mailing services, advertising services, etc.
12. Links to Third Party Websites
The Site and/or the Services and/or the Platform may contain certain links permit Users to leave our Site and/or the Services and/or the Platform and enter non-Curated sites or services. Those linked sites and services are not under the control of Curated 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. Curated reserves the right to terminate any link at any time. You further acknowledge and agree that Curated 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 about you is being collected.
13. Security
We take reasonable measures to maintain the security and integrity of our Site, Services and Platform and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Your Personal Information is hosted on third parties’ servers, which provide advanced strict security standards (both physical and logical). 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. Curated 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 to the extent so required by applicable law. TO THE EXTENT THAT CURATED IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, CURATED 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.
14. Direct Marketing [please confirm]
You hereby agree that we may use your contact details you provided us with (including, without limitation, e-mail address) for the purpose of providing you commercial and/or non-commercial materials related to our current and/or future activities and/or products. You may withdraw your consent by sending a written notice to our e-mail address at: [please add email address] or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you. In addition, we may send push notifications to the User’s device after the User has agreed to accept push notifications from Curated. Users can deactivate push notification by changing their browser settings.
15. Data Retention
Curated will retain the Personal Information for as long as we are confident that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.
16. Changes to the Privacy Policy
Curated reserves the right to change this Privacy 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 Site and/or the Platform 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 Site and/or the Platform 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 Site and/or the Services and/or the Platform 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.
17. Have any Questions?
If you have any questions (or comments) concerning this Privacy Policy, please send us an email to the following address: [Please add email address].