I. Introduction & Overview
Gaviti offers a receivables collection management software.
This Policy defines how Gaviti collects, stores, shares, uses, retains and protects Personal Data (as defined below).
This policy describes the types of Personal Data collected by Gaviti, the way Gaviti uses and protects this information, and to whom it is disclosed.
In this Policy, “Gaviti” or “we” refers to Gaviti Akyl LTD. and its “Affiliates”, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership.
- “Data Subject” – a natural person whose Personal Data is processed by a controller or processor.
- “Identifiable natural person” – means one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- “Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.3 Purpose and Scope
This Policy defines the ways in which Gaviti collects, stores, shares, uses, retains and protects Personal Data.
II. What data do we collect?
Interaction with our website visitors
When you will use the following services through our Website, we will collect and use the following information about you:
- Book a Demo – email.
- Contact us – Full name, email, Phone, Company name and free text.
- Newsletters – email.
In addition, when you use or interact with the website, the following information is created and automatically logged in our systems:
- Log Data: Information (“log data”) that your browser automatically sends whenever you visit the site. Log data includes your IP address (so we understand which country you are connecting from when you visit the site), browser type and settings, the date and time of your request, and how you interacted with the site.
- Device Information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
- Usage Information: Information about how you use our site, such as the types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities.
Gaviti’s platform helps organizations processing their financial data related to their customer’s debt. The service analyzes customers’ invoices and associated risk.
This information includes:
- Customers’ employees: full name, email, job title.
- End customers’ details: full name, phone, address, history of invoices and current monthly payments and etc.
This information is gathered either independently or through the help of Gaviti’s authorized third-party service providers as detailed below.
When you are using the service, we may gather, collect and store the information related to such usage for analysis your usage for improved to portal services.
Employees and Human Resource Data
Gaviti collects personal information from applicants seeking employment with the company, including private contact details, professional qualifications and previous employment history to inform employment decisions.
Once employed, Gaviti collects information about its staff related to their performance, payroll and tax purposes.
III. How do we use the data?
3.1 Interaction with our customers
The data subjects’ email is used only to send them newsletters, updates, pertaining to their order, or to respond to their inquiries, requests and questions.
Data subjects who decide to opt in to Gaviti’s mailing lists will receive emails that may include company news, updates, etc.
Data subjects who wish to unsubscribe from our mailing lists, may do so at any time by following the detailed instructions found at the bottom of each email they receive from Gaviti or by sending request to marketing department email request (“Privacy@Gaviti.com”).
Potential customers who wish to book a demo receive the demo through video service such as Zoom.
Gaviti may use Personal Data to Comply with our legal obligations and resolve any disputes we may have with our customers.
3.2 Interaction with applicants to our job offers
Upon the application Gaviti processes applicants’ data prior to deciding whether they fit our needs. When we decide to hire a person, we process the data to enter into the contract with you.
We will use the personal data we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
In some cases, we need to process data to ensure that we are complying with its legal obligations. For example, it is mandatory to check a successful applicant’s eligibility to work in the countries where Gaviti has offices before employment starts.
Gaviti has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.
If your application is unsuccessful, Gaviti may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before it keeps your data for this purpose for 7 years and you are free to withdraw your consent at any time.
3.3 Cross Border Transfer
As part of its international operations, Gaviti may transfer Personal Data to its Affiliates from time to time for Gaviti legitimate business purposes.
Gaviti transfers Personal Data only if the recipient of the Personal Data has provided appropriate safeguards, and on condition that enforceable Data Subject rights and effective legal remedies for Data Subjects are available.
Personal Data collected may also be processed by Gaviti’s employees operating outside of the European Economic Area or one of its Affiliates or vendors. This staff may be engaged in processing transactions and payment details or provisioning support services. Gaviti vendors are carefully vetted through a vendor assessment procedure and are legally committed to comply with relevant regulations.
3.4 Sharing Information with Third Parties
In all cases of data access and collection, the information provided will not be disclosed, rented, loaned, leased, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely for the purpose stated herein.
Specifically, Gaviti does not share Personal Data with third parties for their direct marketing purposes unless upon specific consent to such disclosure.
Gaviti may share Personal Data with third parties who help Gaviti to maintain, administer or develop its website or handle inquiries from the data subject, sending out newsletters, events or surveys. Gaviti may share data subject information with such third parties, for those limited purposes, for a limited time and only subject to data subject permission.
Gaviti discloses Personal Data to third parties only if they have satisfactory measures to protect Personal Data.
Gaviti cooperates with government and law enforcement officials and private parties to enforce and comply with the law.
We may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
3.5 Legal Basis for Collection
If you are an individual from the European Economic Area, please note that our legal basis for collecting and using your Personal Data will depend on the Personal Data collected and the specific context in which we collect it.
We normally collect Personal Data only where:
- We have your consent to do so;
- Where we need your Personal Data to perform a contract with you (e.g. to deliver the Services you have requested);
- Where the processing is in our legitimate interests; or
- Where we are required to collect, retain or share such information under applicable laws. In some cases, we may need the Personal Data to protect your vital interests or those of another person.
Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Data, you have the right to object.
If you have any questions about or need for further information concerning the legal basis on which we collect and use your personal data, please contact us through the contact details available below.
3.6 Children Privacy
Processing children’s personal data – for those who are under the age of 16, there is an additional consent or authorization requirement from the holder of parental responsibility. Member States may provide for a lower age by national law, provided that such age is not below the age of 13 years. When a service offering is explicitly not addressed to children, it is freed of this rule.
IV. Your Rights
As an EU resident, you may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
- Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your Personal Data that is in our control.
- Request erasure of your Personal Data.
- Object to the processing of Personal Data by us.
- Request to restrict processing of your Personal Data by us.
- Lodge a complaint with a supervisory authority.
Please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
V. Protecting Your Information
Gaviti follows appropriate data collection, storage and processing practices and suitable security measures in order to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data, and all other data stored on our systems.
Exchange of sensitive and private data between Gaviti’s site and its data subjects happens over a secured communication channel and is encrypted and protected with digital signatures.
Retention periods are determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
The most current version will always be posted on our website (as reflected in the “Last Updated” heading).
VIII. Contact Information
Gaviti Akyl LTD., Yigal Alon 94, Tel Aviv Yafo, Israel.
Last Updated: June 2020