PRIVACY POLICY

This privacy policy (“PP”) explains how Consilium Labs Inc., and its affiliates (the “Company” or “Consilum Labs”) collect, receive, use, store and share personal data in connection with the Consilum Labs website available at https://consilium-labs.com/ (the “Site”). This PP is an integral part of Consilium Labs’s terms of use which are available here, (“TOU”) together with the PP, and the TOU, the “Terms”).

1. Applicability.
   1. This PP is in effect as of the date set forth below.
   2. You (“User”) are not under any legal obligation to submit personal data to Consilium Labs. However, in case User chooses not to submit personal data to Consilium Labs, User might not be able to use the Site, or certain parts thereof.
   3. By attempting to use or access, or by using or accessing the Site, User agrees to be bound by the Terms. If User does not agree with the Terms, User must not use or access the Site.
   4. The Company may, from time to time, modify this PP on the Site, therefore User should check back periodically. If User does not agree with the PP, as amended, User must stop using the Site. Any changed PP will be effective from the date it is posted on Consilium Labs’s Site. If Consilium Labs makes any changes to this PP that materially affect Consilium Labs’s practices with regard to the Personal Data Consilium Labs previously collected from User Consilium Labs will endeavor to provide User with notice in advance of such change via email notification or notification via the Site. Consilium Labs will seek User’s prior consent to any material changes, if and where this is required by Applicable Data Protection Laws. User is advised that if User does not terminate all use of the Site, User will be deemed to have accepted the PP, as amended.
   5. Any capitalized terms which are not defined herein shall have the meaning assigned to them in the Consilium Labs TOU.
   6. For the purposes of this PP “Applicable Data Protection Laws“ means (i) the General Data Protection Regulation (2016/679), including any subordinate or implementing legislation (“GDPR”); (ii) the California Consumer Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq., including any subordinate or implementing legislation (“CCPA”), and/or (ii) Protection of Privacy Law 5741-1981 (Israel); and any rules or regulations that amend and/or replace any of the aforementioned Applicable Data Protection Laws.
2. Personal Data collected by Consilium Labs.
   1. Information provided by User.
      1. Information provided by User voluntarily when using the Site e.g. when User submits the User’s contact information on the “Contact Us” page on the Site when pressing the “send message” button (or any other similar button on such page), including but not limited to User’s name, surname, email address, phone number, and User’s query/comment via the Site.
      2. Any communication between User and Company (e.g. emails, phone conversations chat sessions).
      3. User hereby represents and warrants that in providing the Company with the above Personal Data(i) User fully complies with any applicable laws (including without limitation that User obtained and will continue to obtain the consents required by any applicable law); (ii) User will conspicuously display, maintain, and make accessible any privacy policy that complies with any applicable law.
   2. Data collected automatically.
      Consilium Labs may automatically collect data when User visits, interacts with, or uses the Site, including but not limited to:
      1. Identifiers and information contained in cookies;
      2. Content User viewed or searched for, page response times, and page interaction information (such as scrolling, clicks, and mouse-overs);
      3. Network and connection information, such as the Internet protocol (IP) address and information about User’s Internet service provider;
      4. Device information, such as browser type and version, operating system, or time zone setting; location of the device.
3. The Company’s Use of Personal Data.
   1. The Company processes User’s personal data to operate, provide, and improve the Site, including but not limited to:
      1. contacting User by Consilium Labs and communicating with User with respect to the Site, e.g. by phone, email; responding inquiries from User;
      2. informing User about updates or offers;
      3. marketing and promoting the Site;
      4. providing assistance and support;
      5. fulfilling User requests; meeting contractual or legal obligations;
      6. protecting Users security, e.g., preventing and detecting fraud;
      7. internal purposes, e.g., trouble shooting, data analysis, testing and statistical purposes.
      8. Except as provided herein, Consilium Labs does not use any Personal Data other than as necessary to provide the Site, without obtaining User’s prior consent.
4. Personal Data Collected by Third Parties.
   1. This PP does not apply to any products, services, websites, links or any other content that are offered by third parties on the Site. User is advised to check the applicable third party agreements, and/or other third party policies. Consilium Labs does not have any control over such third parties’ privacy practices, or the technology used by such third parties in order to collect any personal data. Each User is advised to thoroughly review such third parties’ privacy policies before making any use of such third party’s products and services.
   2. Without derogating from the generality of the above, when clicking on certain social media links provided on the Site (e.g. Twitter, Facebook, LinkedIn, Instagram, Consilium Labs’s Podcast, YouTube) User will be transferred to Consilium Labs’s sites on such social media (“Social Media Sites”). It shall hereby be clarified that such Social Media Sites are governed by the terms of use and privacy policy of the respective social media and not by the Company.
5. Cookies.
   1. To facilitate and customize the User’s experience of the Site and to track User’s use of the Site, Consilium Labs may utilize cookies and other industry standard technologies. A cookie is a small text file that is stored on a User’s computer for record-keeping purposes which contains information about that User. Most browsers automatically accept cookies, but User may be able to modify its browser settings to decline cookies. Please note that if User declines or deletes these cookies, some parts of the Site may not work properly.
   2. By clicking on a link to a third-party website or service on the Site, a third party may also transmit cookies to User. This PP does not cover the use of cookies by any third parties, and Consilium Labs is not responsible for such third parties’ privacy policies and practices.
   3. Without derogating from the foregoing, please note that the Company may use analytic tools such as Google Analytics. Please click on www.google.com/policies/privacy/partners/ in order to find out how Google Analytics collects and processes data.
   4. Google Universal Analytics. Consilium Labs may use “Google Universal Analytics” in order to gather information about the Users’ use of Consilium Labs Site. Therefore, Consilium Labs stores a unique ID on Users’ device. User may opt-out from this data processing at any time by visiting User Google Account settings and turning off cross-device user analysis. Please click on: https://support.google.com/analytics/answer/2838718, in order to find out how Google Universal Analytics collects and processes data.
   5. Consilium Labs may use facebook pixels. with respect to consilium labs‘s use of facebook pixels please note the following:
      1. third parties, including facebook, may use cookies, web beacons, and other storage technologies to collect or receive user’s information from the site and elsewhere on the internet and use that information to provide measurement services and target ads;
      2. user can opt-out of the collection and use of information for ad targeting;
      3. a mechanism for exercising such opt-out choice can be found at:
         1. See the data protection notice of Facebook for more information on how to protect your privacy: https://www.facebook.com/about/privacy/.
         2. You can also disable the “Custom Audiences” remarketing feature in advertisement settings at https://www.facebook.com/ads/preferences/. For this you have to be logged in to Facebook.
         3. If you do not have a Facebook account, you can opt out of Facebook Commercial Advertising on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/uk/your-ad-choices.
   6. Hotjar
      1. Without derogating from the foregoing, please note that Consilium Labs may use analytic tools such as Hotjar in order to better understand User’s needs and to optimize the Services and experience. Hotjar is a technology service that helps Consilium Labs to better understand Users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what Users do and don’t like, etc.) and this enables Consilium Labs to build and maintain the Services with User feedback. Hotjar uses cookies and other technologies to collect data on Consilium Labs’s Users’ behavior and their devices. This includes a device’s IP address (processed during User session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display Consilium Labs website. Hotjar stores this information on Consilium Labs’s behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on Consilium Labs’s behalf. Please click on https://www.hotjar.com/legal/policies/privacy/ in order to find out more on how Hotjar collects and processes data.
   7. LinkedIn – “Insight-Tag”:
      1. Consilium Labs may also use conversion tracking on the Site with LinkedIn Insights Tag, a tool from LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“Linkedin”). For this purpose, the LinkedIn Insight tag is integrated on the Site and a cookie is set on User device by LinkedIn.
      2. LinkedIn receives information when Users visited Consilium Labs Site and User IP address is collected. Timestamps and events such as page views are also stored. This enables Consilium Labs to statistically evaluate the use on the Site for the purpose of optimization on of the Site.
      3. Consilium Labs learn, for example, which LinkedIn ad or interaction on LinkedIn brought Users to the Site. This allows Consilium Labs to better control how certain ads are displayed on the Site.
      4. Please click on https://www.linkedin.com/help/linkedin/answer/67595/linkedin- conversion-trackingubersicht, for more information on Conversion Tracking.
      5. Users should be aware that LinkedIn’s data can be stored and processed so that a connection to the respective user profile is possible and LinkedIn can use the data for its own advertising purposes. Please click on https://www.linkedin.com/legal/privacy-policy, in order to find out how LinkedIn collects and processes data.
      6. Users can prevent LinkedIn from analyzing users usage behavior and from displaying interest-based recommendations at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
   8. Twitter universal website tag
      1. Consilium Labs may use Twitter Universal Tag from Twitter Inc. (“Twitter”) for conversion tracking (e.g to track events and page views). Users may opt out of Twitter retargeting in your Twitter settings. in order to find out more about the purpose and scope of the data collected, processed and used, please refer to Twitter’s privacy policy located at: https://twitter.com/de/privacy.
   9. The Company uses anonymous, statistical or aggregated information, which may be based on Personal Data provided by User, for legitimate business purposes including for testing, development, control and operation of the Site.
6. Sharing Personal Data of Users.
   1. The Company may be required to retain or disclose Personal Data, without notification, in order to:
      1. comply with applicable laws or regulations;
      2. comply with a court order, subpoena or other legal process;
      3. respond to a lawful request by a government authority, law enforcement agency or similar government body (whether situated in User’s jurisdiction or elsewhere);
      4. engage with third-party service providers and/or sub-contractors which provide services for Consilium Labs’s business operations (such as sub-contractors auditors), a list of which can be received upon request;
      5. disclose to third parties aggregated or de-identified information about Users for marketing, advertising, research, or other purposes;
      6. Consilium Labs believes release is appropriate to comply with the law, enforce or apply Consilium Labs’s terms and other agreements, or protect the rights, property, or security of Consilium Labs, Users, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
      7. To verify the information obtained by Company;
      8. If Company believes that User’s conduct on or in connection with the Site is inappropriate and inconsistent with generally accepted norms of behavior;
      9. In the event that Company, or any of its businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, data may be one of the assets sold or merged in connection with such transaction. Personal Data may also be disclosed in connection with a commercial transaction where Company or any of its businesses are seeking financing, investment, and support or funding.
   2. When Company shares data with third parties, as specified above, Company makes reasonable efforts to require such recipients to agree to only use such Personal Data Consilium Labs shares with them in accordance in accordance with this PP and Company’s contractual specifications and for no other purpose than those determined by Company in line with this PP. However, it is clarified that Company is not liable for such third parties’ use of the Personal Data.
7. Security.
   Company has taken appropriate technical and organizational measures to protect information Company collects from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. User should be aware, however, that no data security measures can guarantee 100% security.
8. Retention.
   Consilium Labs will retain Users Personal Data for a period of time consistent with the original purpose of collection (see Section ‎3, “The Company’s Use Personal Data”). Consilium Labs determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of Users Personal Data processed, the potential risk of harm from unauthorized use or disclosure of Users Personal Data, and whether Consilium Labs can achieve the purposes of the processing through other means, as well as on the basis of Applicable Data Protection Law requirements (such as applicable minimum statutory retention requirements). After the expiration of the applicable retention periods, Consilium Labs will delete Users Personal Data. If there is any data that Consilium Labs are unable, for technical reasons, to delete entirely from Consilium Labs’s systems, Consilium Labs will put in place appropriate measures to prevent any further use of such data.
9. Access to Information.
   1. Depending on Applicable Data Protection Law, User may be entitled to access User’s data held by Company with respect to such User. User’s right of access can be exercised in accordance with the relevant data protection legislation. Any request for access may be subject to a fee to meet Company’s costs in providing such User with details of the data the Company holds on User.
   2. Company will take reasonable steps to verify User’s identity before granting User access or enabling User to make corrections.
   3. If at all, Company will retain Personal Information only for the time period needed for business purposes or as required by applicable law and will securely destroy such information thereafter.
10. Users in the European Economic Area (EEA).
    1. Legal Basis for Processing of Personal Data. Company will only process User’s Personal if it has one or more of the following legal bases for doing so:
       1. Contractual Necessity: processing of Personal Data is necessary to enter into a contract with User, to perform Company’s contractual obligations to User, to provide the Services, to respond to requests from User, or to provide User with customer support;
       2. Legitimate Interest: Company has a legitimate interest to process User’s Personal Data;
       3. Legal Obligation: processing of User’s Personal Data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or
       4. Consent: processing of User’s Personal Data with User’s consent.
    2. User’s Rights regarding Personal Data.
       1. Subject to applicable law, User has certain rights with respect to User’s Personal Data, including the following:
          1. User may ask whether Company holds personal data about User and request copies of such Personal Data and information about how it is processed;
          2. User may request that inaccurate Personal Data is corrected;
          3. User may request the deletion of certain Personal Data;
          4. User may request Company to cease or restrict the processing of Personal Data where the processing is inappropriate;
          5. When User consents to processing User’s Personal Data for a specified purpose by Company, User may withdraw User’s consent at any time, and Company will stop any further processing of User’s Personal Data for that purpose.
          6. In certain circumstances, Company may not be able to fully comply with User’s request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Company will still respond to notify User of such a decision.
       2. User can exercise User’s rights of access, rectification, erasure, restriction, objection, and data portability by contacting Company at [email protected]. In some cases, Company may need User to provide Company with additional information, which may include Personal Data, if necessary to verify User’s identity and the nature of User’s request.
    3. Transfer of User’s Personal Data outside of the EEA.
       1. Personal Data may be processed outside User’s jurisdiction, and in countries that may not provide for the same level of data protection as User’s jurisdiction. The Company ensures that the recipient of User’s Personal Data offers an adequate level of protection, for example by entering into the appropriate data processing agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR).
       2. Company currently stores User data in Company’s data centers located in the USA and in Israel.
       3. Without derogating from the generality of the foregoing, when transferring data from the EEA to Israel, Company relies on the European Commission’s decision that Israel offers adequate data protection for transfers from the EEA.
11. Users in California, USA
    To the the CCPA is applicable the following shall apply:
    1. The Company will only process Personal Data on User’s behalf.
    2. The Company will (i) not collect, retain, use, or disclose Personal Data for any purpose other than for the specific purposes set out in the PP, or any other agreement between Company and User; (ii) not sell Personal Information (as defined under the CCPA); and (iii) put in place appropriate technical and organizational measures to protect personal information against unauthorized or unlawful processing or accidental destruction, loss or damage.
12. International Storage.
    Each User is advised to be aware that Personal Data Consilium Labs collects may be transferred to, processed and stored outside User’s jurisdiction, and that Applicable Data Protection Laws in the jurisdiction where the information is collected stored and/or processed may differ from User’s jurisdiction. Each User hereby gives User’s consent to this transfer, processing and storage of User’s information outside its jurisdiction.
13. Personal Data of Children.
    The Site is not intended for children. Children under 18 years of age, may use the Site only with the involvement of a parent or guardian.
14. Questions Regarding Privacy at Consilium Labs?
    If User has any questions about this PP or Company’s data practices in general, User may contact Company using the following information:
    Email: [email protected]

Last update: November 2022