PRIVACY Notice

Prismm, Inc.

 

Last Updated: February 2024

Protecting your privacy is important to Prismm. With this in mind, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of Personal Information that we receive through the Website and/or the Platform. When we say “Personal Information” we mean information that relates to natural persons and can – either on its own or in combination with other information – identify an individual. Personal information does not include data that has been de-identified or aggregated such that you can no longer be identified.

Scope of this Privacy Notice

Prismm collects and processes Personal Information of individuals sometimes as a controller (in relation to its customers’ or prospect customers’ contact persons and authorized users of the Prismm products and services procured by Prismm customers), and sometimes as a processor (when it processes personal information about third parties (let’s call them, “Guests”) that is collected through direct upload by Prismm customer or that it otherwise collected from the use of Prismm product by Guests.

The processing of Personal Information related to Guests (“Guest Personal Information“) is made by Prismm as a Processor and is covered exclusively under Prismm’s Data Processing Addendum, which forms part of our customer agreements.

The processing of Personal Information related to our Website visitors, people using our Products as authorized users on behalf of our Customers (other than Guests) (“Users“) and prospect customers (“Customer User Personal Information“) is covered under this Privacy Notice.

Please note that if you are a Guest, we process your Personal Information as a processor, thus we act in accordance with our customers documented instructions. for any Guest query or request related to your Personal Information, please directly contact the venue or event owner related to your request/query, as the case may be (they may use our assistance in providing any information to you).

This Privacy Notice describes the Personal Information processing of Prismm, Inc. and all of its Affiliates.

This Privacy Notice does not apply to any third-party websites, services or applications, linked to or accessible through our products or website.

Unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in the applicable legal terms and conditions (“Terms”).

What Personal Information We Collect and for What Purposes

Click on the following products to find out what personal information we process, for what purpose, and, where applicable (in relation to our controller operations) – also the legal basis for processing.

1. Ops and Vision Products (when we act as processors)

2. Users Personal Information (When we act as controllers)

 

3. Information we always collect.

The following is information that is applicable to almost all of the activities detailed above.

We may collect certain information automatically when you use the Website and/or the Platform. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Website and/or the Platform, information about the links you click, and other information about how you use the Website and/or the Platform. Such information may be collected by automatic means, such as usage and/or sessions recordings. Information we collect may be associated with accounts and other devices.

 

4. No obligation to provide Personal information

You are not obliged under any applicable law to provide to us any of the above information and you may be able to opt not to disclose your personal data to Company. However, not providing us with certain data may mean that we cannot provide you with certain functionalities or process any requests or access the Website and/or the Platform altogether.

 

5. General Purposes that apply to all of our processing
   • In addition to the above specific descriptions of our uses of Personal Data, we will also process most of the Personal Data for the following purposes:
     • Operate, maintain, and provide to you the Website and Products features and functionality and to provide you with the Services as requested by you.
     • To prevent, detect and fight fraud or other illegal or unauthorized activities, such as unauthorized access, disclosure or use of our products and resources including Personal Information.
     • Monitoring and ensuring the technical stability and health of our infrastructures, network and software operating the products and services.
     • To ensure legal compliance – from our side (to legal requirements that apply to us and to our obligations under the Terms of Use or other services agreements) and from your side (Compliance with laws applicable to you and with the Terms of Use, acceptable use policies and any other agreements we have)
     • Research and analytics for measurement, improvement and optimization of our products, services and sales and marketing.
   • We will not use your Personal Data for any personal profiling and automated decision making regarding you based on such profiling.
   • We limit access to all Personal Information by our employees to those who were specifically authorized by the Company to access your information, as part of their job.
   • We use anonymized, aggregate data, in order to gain insight on how you and other users use the Website and products to optimize and improve them, as well as to plan and optimize our marketing operations.
   • All of the above processing is based on our legitimate business interest (GDPR Article 6(1)(f), except for point 1.6 which is partially based on our legitimate business interest (concerning compliance with terms of use) and partially is processing that is necessary to comply with legal obligations that apply to us (GDPR Article 6(1)(c).
6. Information from Other Sources.
   • We may obtain information about you from other sources, including through third-party applications and services to supplement information provided by you. This supplemental information allows us to verify information that you have provided to Prismm and to enhance our ability to provide the Website and/or the Platform.

 How We Share Your Information

1. 1. No Sale to Third Parties. We do not, and will not, sell any of your Personal Data to any third party for advertising, marketing or any other purpose.

 

1. 1. Service Providers. We employ other companies and people to perform tasks on our behalf and need to share your information with them in order to provide the services to us. The categories of third party recipients of the personal data from us are as follows: Cloud hosting services, email campaign automation, marketing automation, social media advertisement (on our behalf, not for transfer to third parties advertisement or marketing purposes), CRM platform, analytics tools providers, support and maintenance operation tools, payment processing and payment management services, web page building tools, audio and/or video conferencing capabilities providers, recruiting service providers, in relation to activities on the website related to submission and processing of CV and job applications through the website. Our service providers do not have any right to use your personal information collected from our Website and Services beyond what is necessary for the purpose of facilitating the proper provision of the Services and operation of the Website and are subject to appropriate data protection agreements to the extent required under applicable law.

 

1. 1. Compliance with the Law. We may disclose your information if we believe in our sole discretion it’s necessary in order to comply with the law, such as to comply with a subpoena, regulation or legal request, respond to a government request, to respond to claims or conduct a legal process, to address fraud or security issues, to protect the safety or rights of any person or those of a third party or the public in general, to enforce our agreements with you; to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing or unethical conduct, or to protect our own rights or property. If you are located in the EU, we may only do so based on legal requirements specified above of EU authorities. This includes sharing such information with our legal counsel.

 

1. 1. Business Transfers. If we are in a bankruptcy, receivership, merger, acquisition, reorganization or purchase of sale of assets or activities, your information may be transferred as part of that transaction to a successor in interest and to the applicable legal authorities as well as legal counsels and other professional counsels involved such as accountants, and other officers of the government or of the applicable judiciary instance. In addition, we may transfer or provide access to Personal Information in the course of a due diligence process in relation to a contemplated investment, merger or acquisition or a similar transaction.

 

1. 1. Embedded Social Sharing. The Website and/or the Platform may offer various tools and functionalities. For example, Prismm may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use the Website and/or the Platform. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request but will not be collected or otherwise used by Prismm or any other third parties for any other purpose. By using the Products and Services, you hereby warrant and represent that any Personal Information that you provide to us, is provided solely with the consent of the data subject whose Personal Information is being shared with us (When you are a business customer, this will be covered in our DPA; any representations and warranties provide in the DPA shall govern and prevail with respect to any PII transfers you make as a representative of an enterprise customer. When you are using these features as an individual customer, this representation applies to you).

 

1. 1. Sharing Information with your Employer/Patron. If you use our Services on behalf of an organization (e.g., an event organizer), that organization may: (i) access information associated with your use of the Services including usage and other data (e.g., who has accessed, shared, amended, created, edited, or deleted content), and the contents of the communications and files associated with your account; and (ii) control and administer your account, including controlling privacy-related settings (e.g., profile settings including choices relating to displaying a profile image).

 

1. 1. Other Users of the Products. As a collaborative event planning platform, Event information is shared between Account holders (i.e., registered Users) and other Users who are invited to the same Event. For example, as a Host, if you invite another User to your Event page on the Website and/or the Platform, that User will see the Event specific information you have provided to describe your Event, including the event date, number of guests, venue, furniture layout, food preferences, guest list, and other information you choose to make available. With respect to floorplan information, you provide to the Website and/or the Platform, if you specify that the floorplan is a private, the floorplan will only be visible to you and those that you invite to your Event containing that floorplan. In addition, if you register as a vendor, your information will be available to other Users in a searchable directory. If you join an Event, any Host, Vendor or other User associated with that Event will be able to see that you are connected to that Event. The information you provide about your Event is voluntary. We recommend that you guard your sensitive information, and we encourage Users to think carefully about what information about themselves they disclose on their Event pages. In addition, as a Host, you may choose to contact a Vendor through the Website and/or the Platform using our subscription feature. If you click on a “Contact Vendor” link within the Website and/or the Platform, the applicable Vendor will receive your contact information (including name, phone number and email address) and information regarding your Event (such as date, event type, location, venue and number of guests). We are not responsible for any consequences of any use or disclosure of your information by such Vendors and you assume all risk arising from such information sharing and your interaction with such Vendors.

 

1. 1. Business Partners. We may provide Personal Information to business partners to provide you with a product or service you have requested. We may also provide Personal Information to business partners with whom we jointly offer products or services.

 

1. 1. Anonymized Information. We may provide third parties with aggregated but anonymized information and analytics. However, before we do so, we will make sure that it does not identify individuals (and hence it shall not be provided as Personal Information).

 

1. 1. Backups and Shared Responsibility. Prismm is a SaaS provider and therefore, each User is responsible to maintain the integrity of its data and information uploaded to Website and/or the Platform. Each User is also responsible for maintaining the operation and connectivity of its devices, hardware and any other infrastructure required for the access and use of the Website and/or the Platform. Prismm is under no obligation to verify the accuracy, completeness or integrity of any information provided by users, and bears no responsibility in connection therewith. Prismm responsibility to provide access and use of the Website and/or the Platform shall be as set forth in the Terms.

 

Cookies and other tracking technologies

A cookie is a small text file that is stored in your web browser that allows Prismm or a third party (such as third-party service providers) to recognize you and gain some insight about your activities in our Website and Products, sometimes in other sites as well. Some cookies collect and process Personal Information, while some cookies do not do that and only collect and process aggregate data or technical data that is not related to a specific Individual.

Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies.

Cookies that we may use can generally be categorized as follows:

• Necessary Cookies: These cookies are necessary to load the website or the Product and to allow users to use certain features, as well as cookies used to keep you from getting any other cookies to the extent you have not agreed to placement of our cookies to your device/browser.
• Analytics Cookies: These cookies track information about how a website or product is being used (such as number of page visits, time spent on specific sections, source directing the visitor to our site etc.) so that we can make improvements and attribute success or failure factors to certain attributes on our site or product.
• Preference Cookies: These store your website preferences such as language, currency, skins, etc.
• Marketing and targeting (also called retargeting) Cookies: These are usually third-party cookies by advertising platforms or networks used in order to:(i) deliver and tracks ad performance and attribute purchases to certain campaigns, and (ii) enable advertising networks to serve ads that may be relevant to you based upon your activities.
• You may choose to not consent to placement of, or opt out of, any kind of cookies described above, except for Necessary Cookies.
• We may use additional tracking technologies to help understand user activities and preferences. For example, we use web beacons (also known as clear gifs, pixel tags or web bugs) to track user activities on the site/product and communicate with cookies. In addition, clear gifs may be used in our emails correspondence to gain insight on whether our emails were opened, whether any traffic originates from those emails etc. You cannot opt out of web beacons used in webpages, but you can limit their use by opting out of the cookies they interact with. You can opt-out of web beacons used in emails by setting your email client to render emails in text mode only and not download any gif files by default.
• Please check out the cookies preference tool to find out which cookies and other tracking technologies we use, and manage your choices regarding those we may use with your browser or device.
• We may set cookies that monitor links to our website that we send to you (if you have consented to receive emails from us). These cookies are used to track visitors to our website sourced from these emails. To avoid these types of cookies, please follow the explanation below on how to change your browser cookies settings.
• In addition, we may use tracking technology in certain types of emails (e.g., documents sent to you for signature by email or other marketing communications or transactional emails) to gain insight on how often our emails are opened and clicked on by our customers or users. If you do not wish this tracking to be effected, please change your email software or service (such as outlook, Gmail etc.) settings to not automatically download images (to the extent it is not already your default) In some instances, depending on your email or browser settings, cookies in an email may be automatically accepted (for example, when you have added an email address to your address book or safe senders list). Please refer to your email browser or device instructions for more information on this.
• You can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser. Some useful information can also be found here: https://www.allaboutcookies.org/ Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages or product features might not display or function properly.
• We may use certain types of fonts in our products that may function as cookies and collect and send over data to third parties or to us regarding the fonts use, this is mainly due to intellectual property rights embedded in those fonts and will not contain personal information.
• For more information about Google Analytics cookies, please visit google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Website and/or the Platform by going to http://tools.google.com/dlpage/gaoptout.

Your Choices

We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time by contacting us as described below.

Communications

1. 1. We may periodically send you Advertising Material related to Prismm and its partners based on or related to your use of the Website and/or the Platform. You will only receive advertising materials to the extent you have opt in to receive it, unless otherwise permitted in your jurisdiction.
   2. When you receive Advertising Material from us, you will always have the opportunity to “opt-out” (by following the unsubscribe instructions provided in the e-mail you receive).

 

1. 1. We do need to send you transactional communications regarding the Website and/or the Platform and you will not be able to opt out of those communications – e.g., communications regarding Account management or updates to the Website and/or the Platform, the Terms or this Privacy Policy.

Mobile Devices.

We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.

Modifying Your Information.

You can access and modify certain Personal Information associated with your Account through the Website and/or the Platform or by contacting us via email with your request at privacy@Prismm.com. If you would like to exercise any of your rights as set forth in this Privacy Notice please contact us at privacy@Prismm.com with your request. If you contact us we may, for your protection, ask you for additional information to verify your identity.

Use by other Users of your Personal Information

Please note that the Website and/or the Platform allows you to share information with other Account holders.  You understand and agree that if another Account holder has accessed any information that you have shared, including Personal Information, other than putting in place the appropriate contractual provisions, we cannot control what they do with that information outside of the Website and/or the Platform.

Individual Rights in Personal Information

It is your responsibility to ensure that all personal data submitted to Prismm is correct. Prismm would like to make sure you are fully aware of all of your data protection rights. Depending on your location and on the laws that are applicable to you may be entitled to some or all of the following rights:

The right to access – You have the right to request Prismm for copies of your personal data, which includes the right to obtain confirmation as to whether or not personal data concerning yourself are being processed and, where that is the case, access to the personal data and the purposes of the processing; categories of personal data concerned; recipients or categories of recipient to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored; the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling; the appropriate safeguards relating to the transfer of your personal data outside the EEA. We may charge you a small fee for this service under certain conditions.

The right to rectification – You have the right to request that Prismm corrects any information you believe is inaccurate. You also have the right to request Prismm to complete the information you believe is incomplete.

The right to erasure – You have the right to request that Prismm erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that Prismm restricts the processing of your personal data, when: (a) you contest the accuracy of your personal data, for a period allowing Prismm to verify the accuracy of said data; (b) if you believe personal data has been unlawfully processed and you wish to restrict processing rather than delete it; (c) Prismm no longer needs the personal data but you require to keep it in order to establish, exercise or defend a legal claim; or (d) you have exercised your right to object the processing (below) for a period allowing Prismm to consider whether your legitimate grounds override those of Prismm.

The right to object to processing – You have the right to object to the processing of your personal data at any time – this means you have the right to stop or prevent Prismm from processing your personal data (it could be in relation to part or all of your personal data, and for part or all of the processing purposes). When relating to processing for marketing purposes, you have an absolute right to object; while for other purposes, the existence of the right depends on what lawful basis the processing relies on.

The right to data portability – You have the right to request that Prismm transfers the data that we have collected to another organization, or directly to you, under certain conditions.

If allowed by applicable laws, you have the right to withdraw your consent at any time when Prismm processes your personal data based on your consent on any of these rights. However, withdrawal does not affect the legitimacy and effectiveness of how we process your personal data based on your consent before the withdrawal is made; nor does it affect any data processing based on another lawful basis other than your consent.

You may exercise these rights to the extent these rights apply to you by emailing Prismm to: privacy@Prismm.com or use any of the contact information listed below. We will undertake to respond to your request within the applicable time frame prescribed by applicable law. Although we will make reasonable efforts to accommodate your requests, in some circumstances we may deem your request unfounded or not eligible under applicable law. In such instances we reserve the right to refuse your request. We shall require, as pre-requisite to fulfilling any request, to verify your identity which we may do by asking you to provide certain information or identification to ensure that all data subjects’ privacy is protected.

If you think that the way we process your personal information does not comply with applicable data protection laws, you can contact the relevant competent data protection authority. You can obtain the information for contacting EU data protection authorities at https://edpb.europa.eu/about-edpb/board/members_en.

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

International Transfers

The website may be operated in countries other than your own location, and your personal data may be accessed and/or processed from and/or transferred to countries other than your own location. We may do this where data is accessed/processed:

• By Prismm and its affiliates for operational, administrative, compliance purposes or customer support teams in our various locations;
• By our service providers, for the purposes we specified under the section “Service Providers”.

The safeguards we deploy for performing such transfers across boundaries:

• Adequacy. If you are located outside of Israel, and choose to provide information to us, please note that we transfer the data, including personal data, to Prismm’s headquarters located Israel and process it there. Any transfers to Israel may be made on the basis of an adequacy decision made by the European Commission.
• Model Clauses. With some of our processors, we use standard contractual clauses approved by the European Commission that are binding standards of processing of personal data committed to contractually by third parties processing information for us and on our behalf.
• Consent. In the absence of an adequacy decision or Model Clauses, and in the absence of any other right to transfer your data, your consent shall serve as the basis for such transfer. By accessing and using the website, you agree and understand that your information may be transferred from the EEA or other countries in which you may be using or accessing the website, to other jurisdictions outside your own location (including outside the EEA). The transfer will be to such third parties as described under “Service Providers” section below.

Prismm will take steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Data Retention

We retain the Personal Information we receive for as long as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

We will retain your personal data for no longer than is necessary for the purposes stated in this Privacy Policy, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The data storage period may vary with scenario, product, and service. The standards Prismm  uses to determine the retention period are as follows: the time required to retain personal data to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of the website; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention; etc. 

The Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Website and/or the Platform or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website and/or the Platform. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Website and/or the Platform, by mail or by sending an e-mail to you.

To learn more about the technical and organizational measures we deploy to protect the Personal Information, please contact us.

Other Important Information

Responding to Do Not Track Signals

Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.

Links to Other Sites/Applications          

The Website and/or the Platform may contain links to websites and applications that are owned or operated by third parties (each, a “Third-Party Service”). Any information that you provide on or to a Third-Party Service or that is collected by a Third-Party Service is provided directly to the owner or operator of the Third-Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-Party Service. To protect your Personal Information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

Our Policy Toward Children

The Website and/or the Platform are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If we learn that we have collected Personal Information from a child without parental consent, we will take steps to delete such information from our files as soon as possible.

Revisions to this Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Prismm Products and Services after the new Privacy Policy takes effect.

Questions?

If you have any questions about our privacy practices or this Privacy Policy, please contact us at privacy@prismm.com