Privacy Policy • SOSA

This privacy policy describes how we use personal information related to you, along with your options, choices, and privacy rights.

Note that you are not legally obligated to provide us with any personal information. However, if you consent to this privacy policy, the use of personal information related to you will be in accordance with the provisions herein.

Our privacy policy applies to sosa.co (the “Website”) and forms an integral part of the SOSA Terms of Service.

SOSA HOLDINGS LTD., Reg. No. 514620103 and its subsidiaries (collectively, “we”, “us”, “our”, or “SOSA”) own and operate the Website.

This privacy policy was last updated on February 1, 2020, with an effective date as of March 1, 2020, unless required otherwise under applicable law.

If you have questions or comments about our privacy policy, you are welcome to contact us at: Info@sosa.co.

What Services Do We Provide?

SOSA develops and manages a global platform that connects corporations, governments and cities to innovative technologies and ecosystems. In addition, SOSA leases office space to startups (all SOSA’s services collectively will be referred to as the "Services").

What Types of Personal Information Do We Collect and Why?

We collect information about your company, which includes personal information about individuals. In addition, we collect (a) email addresses and billing information to provide you with the Services; (b) personal information to improve our Website, Services, and marketing activities; and, (c) personal information that you have provided us with, for example, when you contact our customer service. We use third-party service providers to hold, maintain, provide, and improve our Services.

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We commit to process personal information related to you solely for the purposes described below.
To the extent relevant and possible, we will make efforts to maintain personal information related to you accurate, complete and up to date.
You can register to our mailing list to receive updates and marketing materials and invitations electronically to our events (for example, see join us, become a partner or contact us).

We share your name and email address with third-party providers to send you email messages.

You can opt-out from the list by simply click on the unsubscribed request written in the received email message.
You hereby provide us with your freely given, specific, informed and unambiguous consent to use your name and email address for our internal and marketing purposes.

This includes, without limitation, sharing of contact details given to us with our clients, in order to contact you for business related opportunities.
If you use our Services to send emails to others, you acknowledge and agree to obtain their sufficient consent and send these email messages at your sole responsibility and risk.
If you contact our customer service, we will use the content of your message for the following purposes: (i) addressing your request; (ii) improving the Website and Services; and, (iii) legal defense, where applicable.
We will also process personal information related to you to improve the Website, establish statistical data about our web traffic, identify potential cases of abuse of our systems, as well as prevent cyber-attacks, fraud, and identity theft.
To the extent that we utilize third-party processors or providers to process personal information, we engage with them under a data processing agreement to ensure we have their contractual commitments to protect personal information and process such personal information for specific purposes. Our main marketing activities online include -
- Google Display Network’s marketing services and features that SOSA uses, which are also subject to Google’s relevant policies and agreements and the option to opt-out from them via the Google Analytics Opt-out Browser Add-on web page, available here: tools.google.com/dlpage/gaoptout.
- Facebook’s marketing services and features that SOSA uses, which are also subject to Facebook’s relevant policies and agreements and the option to opt-out from them via the Facebook relevant help center page, available here: www.facebook.com/help/568137493302217.
- Twitter’s marketing services and features that SOSA uses, which are also subject to Twitter Ads policies and agreements and the option to opt-out from them via the Twitter help center page, available here: help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.
- Instagram’s marketing services and features that SOSA uses, which are also subject to Instagram Business policies and agreements and the option to opt-out from them via the Instagram Business help center page, available here: help.instagram.com/196883487377501, as well as the “What can I do if I see an ad I don't like on Instagram?” page, available here: help.instagram.com/615366948510230.
We report and share personal information if we believe that we are required to do so by law. Furthermore, we need to disclose personal information in response to lawful requests by public authorities, including without limitation to meet national security or law enforcement requirements.
There are business activities, such as merger, acquisition, or investment, that require us to share personal information related to you to another entity, provided, however, that the receiving entity will comply with the relevant provisions stated in this privacy policy.
Your interaction with social media features, widgets, or websites are governed by the privacy policies of the applicable social media websites.
If you contact us via these social media websites, we will use the content of your message for the following purposes: (i) addressing your request; (ii) improving our Website and Services; and, (iii) legal defense, where applicable.

We are not responsible for any use, misuse or unlawful use of the identifiable information that you choose to post or share on these platforms.
We gather some information automatically, such as IP addresses, browser type, internet service providers, referral links, geo-locations and clickstream information.

If these types of information include personal information, it will be used in accordance with this privacy policy and for the following purposes: (i) provide you with the Services; (ii) improving our Website and Services; and, (iii) legal defense, where applicable.

Note that we use Google Analytics. Google Analytics uses personal information collected through the Website for purposes other than for providing us services. Please read carefully Google Analytics’ privacy policy, available here: policies.google.com/privacy?hl=en-US. You can opt-out from Google Analytics by visiting here: tools.google.com/dlpage/gaoptout.
We process aggregated data that is not personally identifiable information. For example, we use statistical analysis to improve our Services and share marketing data with our partners where such data do not identify individuals.

What Cookies Do We Use?

We store cookies on your device to enhance site navigation, analyze site usage, and assist in SOSA’s marketing efforts. You can manage your cookie preferences. Read More at our Cookie Policy.

What Choices Do I Have?

You can opt-out of our mailing list and terminate your use of the Website. Our Services do not respond to Do Not Track (DNT) signals.

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You can contact us at Info@sosa.co and request access to the personal information that we keep about you. You can also request to correct wrong details collected about you or delete them. We will consider your request in accordance with applicable laws and regulations.
To the extent necessary, we will ask you to provide us with certain credentials or details to make sure that you are who you claim to be.
Note that we can delete personal information related to you in different manners, including by removing any identifying information and transforming personal information that relates to you into anonymized data.

What Personal Information Can I Access?

You can request access to personal information that we keep about you. You can also request us to correct wrong details about you or delete them from our systems.

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You can contact us at Info@sosa.co and request access to the personal information that we keep about you. You can also request to correct wrong details collected about you or delete them. We will consider your request in accordance with applicable laws and regulations.
To the extent necessary, we will ask you to provide us with certain credentials or details to make sure that you are who you claim to be.
Note that we can delete personal information related to you in different manners, including by removing any identifying information and transforming personal information that relates to you into anonymized data.

For How Long Do We Keep Your Personal Information?

We retain data as needed, to provide our Services and for legitimate and lawful purposes. We implement information security measures to secure personal information related to you as well as minimize the risks.

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We retain data as needed to provide our Services as well as for legitimate and lawful purposes. We also retain data pursuant to legal requirements under applicable laws.
We will make efforts to guarantee that personal information is kept for no longer than is necessary for the purposes for which the personal information is processed.
If we retain personal information related to you for any legitimate business purpose other than to provide our Services, we will make efforts to limit the access to the personal information and the retention time to minimum.
Note that we can keep aggregated non-identifiable data without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the data.

How Do We Keep Your Personal Information Secured?

We implement information security measures, including internal policies and procedures, to secure personal information related to you as well as minimize the risks of theft, damage, loss of data, or unauthorized access.
These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that our Services will be immune from any wrongdoings, malfunctions, unlawful access or other kinds of abuse and misuse.

Where Do We Store and Process Your Personal Information?

We store and process personal information in the United States, the United Kingdom, Germany, France, and Israel.

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We store and process personal information in the United States, the United Kingdom, Germany, France, and Israel, including sites operated and maintained by cloud-based hosting service providers in the U.S.
When we transfer personal information related to you out of the European Union, our transfer of personal information related to you to our cloud-based hosting service providers in the U.S. is governed by these service providers’ adherence to the Privacy Shield Framework. Please read more about the protection of personal information under this framework at www.privacyshield.gov.
If you are a resident in a jurisdiction where transfer of personal information related to you to another jurisdiction requires your consent, then you hereby provide us with your freely given, specific, informed and unambiguous consent to such transfer.

How Do We Notify You of Changes to this Privacy Policy?

We can update our privacy policy from time to time after giving a proper notice.

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From time to time, we can update this privacy policy. We will post a notice about changes made to this privacy policy on the Website or via email (the "Notice").
Unless required otherwise to comply with applicable laws, rules, regulations, and agreements, all minor changes (which have minor, if any, consequences) will take effect 7 days after we post or send the Notice, and substantial changes will be effective 30 days after we post or send the Notice.
Until the new privacy policy takes effect, you can choose not to accept it and terminate your use of the Website and Services. Continuing to use the Website or Services after the new privacy policy takes effect means that you agree to the new privacy policy.
Note that we can modify, enhance or improve the Website and Services, and can accordingly offer additional tools and features. Where necessary, at our sole discretion, such additional tools and features will be governed by additional or different terms, as provided by us.

Supplement A: EU Data Subjects’ Privacy Rights (GDPR)

If the European Union data protection laws applies to the processing of personal information related to you, this Supplement A is also relevant for you.

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If the European Union data protection laws apply to the processing of personal information related to you by SOSA, then, as of May 25, 2018, the following information, rights and obligations also apply.
We process personal information related to you for the following lawful grounds -
- All processing of personal information related to you which are not based on the lawful grounds indicated below, are based on your consent.
- We process your account and payment details to perform the contract with you.
- We will process personal information related to you to comply with legal obligations and to protect your and others’ vital interests.
- We will further rely on our legitimate interests, which we have good-faith belief that they are not overridden by your fundamental rights and freedoms, for the following purposes -
  - Communications with you, including direct marketing where you are our client, or a user of our client, or where you contact us or show interest in our services through our Site and other digital assets.
  - Cyber security.
  - Support, customer relations, service operations.
  - Enhancements and improvements to your and other users’ experience with our services.
  - Fraud detection and misuse of our services.
In addition to your rights under other sections in this privacy policy, you have the following rights -
- Contact us if you want to withdraw your consent to the processing of personal information related to you. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
- Request to delete or restrict access to personal information related to you. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
- If you exercise one or more of the above-mentioned rights, in accordance with the provisions of applicable law, you can request to be informed that third parties that hold personal information related to you, in accordance with this privacy policy, will act accordingly.
- You can ask to transfer personal information related to you in accordance with your right to data portability.
- You can object to the processing of personal information related to you for direct marketing purposes. Additional information about this right is available under the Choice section in this privacy policy.
- You have the right not to be subject to a decision which is based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affecting you.
- You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
- A summary and further details about your rights under the European Union data protection laws, is available on the European Union Commission’s website: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
- Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will ask you further questions to understand the nature and scope of your request.
- If we need to delete personal information related to you following your request, it will take some time until we completely delete residual copies of personal information related to you from our active servers and our backup systems.
We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this privacy policy, update the privacy policy when we believe that we need to, and verify that we display the privacy policy properly and in an accessible manner.
If you have any concerns about the way we process personal information related to you, you are welcome to contact our data protection team at Info@sosa.co. We will investigate your inquiry and make good-faith efforts to resolve any existing or potential dispute with you.
You are welcome to contact our representative in the European Union which is contact details are as follows: Rickert Rechtsanwaltsgesellschaft mbH, Kaiserplatz 7-9, 53225 Bonn, Germany; email address: datenschutz@rickert.net.