PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

The sources from which we obtain personal information are:

• Directly from our User (either actively or through automatic monitoring of use of the Services).
• Third parties who assured us that they have obtained Visitors’ consent for such provision of information.

We collect and share personal information for the following purposes: To perform the contractual obligations between us and our customer, the Subscriber, which is your employer; To provide and improve our Services, Platform, Apps and manage our business; To send you updates, notices, notifications, announcements, and additional information related to the Services; To be able to manage your account and provide you with customer support; To conduct surveys regarding our Services or regarding the Users’ experience of our Platform; To display or send you marketing and advertising material and general and personalized content and advertisement; To develop, display and track content and advertising tailored to your interests on our Service and Platform, including providing our advertisements to you when you visit other sites; To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our Site, Platform and Apps; To verify your eligibility and deliver prizes in connection with contests and sweepstakes; To perform functions or services as otherwise described to you at the time of collection; To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities; To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.

We do not put your data on the open market, act as data brokers or otherwise trade in your data. However, certain standard generally accepted business practices maybe deemed as “Sale” of data under the CCPA, such as when we utilize third party service providers that provide us with services, while they retain certain ability to use your data for their own business needs (e.g. Google Analytics and Facebook).

If you are a California customer, you have a right to request to opt-out of the “sale” and “sharing” of certain personal information. Please refer to section 4, “Your California Consumer Rights”, below for information on how you can exercise your rights.

For more details on how and to whom we transfer your data please refer to the Section titled “Sharing Information with Third Parties” in our Privacy Policy.

1. RIGHT TO ACCESS
   California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may make this request up to two times in a 12-month period.You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the Business or Commercial purposes for collecting, Sharing, Selling, or otherwise disclosing your personal information, the categories of third parties with whom we share, sell or otherwise disclose your personal information, the categories of personal information we have disclosed and “sold” or “shared” about you in the preceding 12 months, and the categories of third parties to whom we sold or shared personal information in the preceding 12 months.
2. RIGHT TO DELETE
   If you are a California consumer, you also have the right to request deletion of your personal information, subject to certain applicable legal exceptions.
3. RIGHT TO NON-DISCRIMINATION
   You have the right to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights. Unless otherwise permitted by applicable law (such as if the differences are reasonably related to your information), we will not:
   • Deny you goods or services;
   • Charge different prices or rates for goods or services, including through the use of discounts or other benefits, or imposition of penalties.
   • Provide a different level or quality of goods or service; or
   • Suggest that you will receive a different price or rate for goods or services, or a different level or quality of goods or services.

    

4. RIGHT TO LIMIT OR OPT OUT OF SALE OR SHARING OF PERSONAL INFROMATION
   Our Services do not sell (as “sell” is traditionally defined) your personal information. That is, we don’t provide your name, phone number, address, email address or other personally identifiable information to third parties in exchange for money. However, under California law, certain cases of sharing information, such as for advertising purposes, may be considered a “sale” of “personal information.” If you’ve visited our digital properties within the past 12 months, personal information about you may have been “sold” under the CCPA to our advertising or other partners for their own use. If you are a California consumer, you have the right to opt-out of the “sale” and “sharing” of personal information.We may collect certain categories of information that is considered “sensitive personal information” under California law. You have the right to limit the use and disclosure of your sensitive personal information to whatever is necessary for us to make Services available to you.Please note that by opting out of the sale or sharing of your personal information:
   • You may still see some tailored advertising that third parties may have previously collected unless you opt out of all interest-based advertising;
   • We will still share your personal information with our service providers to the extent required to continue providing the Services; and
   • These settings may not persist if you clear your cookies, switch devices, or switch browsers. If you access our websites from other browsers or devices, you will also need to make this selection on each browser and device. If you delete or clear cookies, you’ll need to click the button again the next time you visit. If you delete or clear your cookies, that will delete our opt-out cookie and you will need to opt out again. If you have previously requested that we do not sell your personal information, your request remains in effect until you tell us otherwise.
5.  HOW TO MAKE CCPA REQUESTS?To make a request regarding any of your rights (as described above), please send your request to privacy@centrical.com. Your request must include sufficient information that allows us to reasonably verify that you are the person about whom we collected the personal information. To that end, before completing your request, we may need to verify your identity or the identity of your authorized representative.After you submit a request to exercise a right as described above (other than a request to stop the sale or sharing of your personal information or to limit the use and disclosure of your Sensitive Personal Information), we will acknowledge receipt of your request within 10 business days of receipt of your request and your request will continue to be processed.We generally provide a response to your request within 45 days from the date when the request was received, however we may be allowed to take longer under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

   We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.

   For requests to opt out of the sale or sharing of your personal information or request to limit the use and disclosure of your sensitive personal information, we will comply within 15 business days after receipt of your request.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:

Centrical

Email: privacy@centrical.com

Address:  4 HaSheizaf St, Ra’anana, Israel