Privacy Policy

Last update: April 2020

ToGo Networks ("Company", "we", "us" or "our") respect your privacy and recognize that your privacy is important. This privacy policy ("Privacy Policy") sets forth and governs the privacy practices of the Company and applies to users that access this Websites owned and operated by the Company and the Services therein. This Privacy Policy is an integrated part of our Terms and Conditions ("Terms"). Definitions herein shall have the meaning assigned to them in the Terms. It is your responsibility to read this Privacy Policy thoroughly.

If you have any questions about this Privacy Policy, please contact us at: support@togonetworksltd.com.

Depending on your interaction with the Website, we may collect two types of data from you, as follows:

The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Website ("Non-personal Data"). We are not aware of the identity from which the Non-personal Data is collected. Non-personal Data which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website's domain name from which you linked to the Website, etc.), in order to enhance the functionality of the Website. We may also collect information about your activity on the Website (e.g., how many users visited the Website, which pages were viewed, etc.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Data"). Personal Data may include:

• Contact Us Information: You may contact us through the communication means we make available to ask any question you may have or for other reasons. If you contact us, we may collect any information contained in any correspondence (e.g., your full name, email address and free text). We will use your contact details and save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other information requested by you.

• Voluntarily Information: We may collect information that you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Website.

• Device Information: We may collect Personal Data from your device. Such information may IP address, unique identifiers, as well as other information that relates to your activity through the Website. We use this data , as well as technical Non-Personal Data for the purpose of our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Website and Services and the way in which we offer them; our legitimate interests of auditing and tracking usage statistics and traffic flow, detecting security or technical issues in connection with the Website; and internal statistical and analytical purposes as well as evaluating and optimizing the user experience.

If we combine Personal Data with Non-Personal Data, the combined data will be treated as Personal Data for as long as it remains combined.

We will not share your Personal Data with third parties, outside as specifically mentioned herein:

• User’s explicit consent - we may disclose your Personal Data to third parties upon your explicit consent. Please note that once we share your information with third party, that information becomes subject to the other third party’s privacy practices;

• Policy enforcement - we may disclose or share your Personal Data, solely to the extent needed to enforce our policies (including our policies and agreements) and to establish or exercise our rights to defend against legal claims, as well as investigations of potential violations thereof, including without limitations, investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud, security or technical issues;

• Third party rights - we may share your Personal Data in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of our users or any applicable third party;

• Law enforcement - we may disclose or share your Personal Data, solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with courts injunction, comply with tax authorities, etc.);

• Affiliate company and corporate transaction - we may disclose or share your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under common control ("Affiliated Companies") solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;

• Service providers - we may disclose Personal Data to our service providers to perform requested services on our behalf. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make informed decisions about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Data, according to applicable data protection and privacy laws.

Privacy laws differ from jurisdiction to jurisdictions, each of which may provide you with different rights regarding your Personal Data. For your convenience, please see below a list of rights that you may be entitled to exercise in accordance with the applicable data protection laws that apply to you.

• The right to be informed – you have the right to be provided with information regarding our data collection and privacy practices, as described in this Privacy Policy.

• The right to access your information - you have the right to request a confirmation that we process your Personal Data, and under some circumstances, be provided with a copy of your Personal Data that we process.

• The right to be forgotten - you have the right to require the erasure of certain Personal Data, if specific conditions are satisfied (if the Personal Data is no longer needed for the original purpose and there is no new lawful basis for continued processing); if you have exercised your right to withdrawn consent (in the event applicable), or to object to the processing and we have no overriding grounds for the continued processing; the Personal Data is processed unlawfully; or erasure of Personal Data is necessary to comply with applicable legislation. Please note that this right is not absolute. We may not accept a request under certain circumstances, among others where we must retain the applicable Personal Data in order to comply with our legal obligations or defend against legal claims, etc.

• The right to object - you have the right to object to our processing of your Personal Data, in the event the legal basis for processing is our legitimate interests. Notwithstanding the above, we will be permitted to continue the processing of such Personal Data if our legitimate interests override your rights, or when the processing is necessary to establish, exercise or defend a legal claim, etc.

• The right to restrict processing - you may be entitled to limit the purposes for which we process your Personal Data. This right is applicable when: the accuracy of the Personal Data is contested; the processing of the Personal Data is unlawful and you requests restriction instead of erasure; the Personal Data is no longer needed for the original purpose it was collected, however it is still required to establish, exercise or defend legal rights; or there are overriding grounds in the context of an erasure request;

• Rectification - you have the right to require to update Personal Data which is not correct;

• Data Portability - you have the right to have your Personal Data "port" to a third-party;

• File a complaint - You may also be entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy

If you wish to submit a request to exercise any of your rights, please send your request to: support@togonetworksltd.com. Note that, we will require certain information from you in order to verify your identity and locate your information. This may take reasonable time, and subject to applicable law requirement. At any time, you have the right to contact your local data protection authority. If we require more time, we will inform you of the reason and extension period in writing. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. We retain the Personal Data we have collected for as long as needed to provide the Service, carry out our business purpose and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed below.

The Company incorporates high standards to protect the collected information. The Company shall continue to use reasonable commercial efforts to ensure the protection of the information. Notwithstanding the above, please keep in mind that no data transmission over the Internet can be protected 100% from intrusions. Therefore, while we strive to use commercially reasonable means to protect your information, we cannot guarantee its absolute security. The Company makes efforts to mitigate such risks.

If you believe that your privacy was not treated in accordance with our Privacy Policy, or if any person attempted to abuse our Website or acted in an inappropriate manner, it will be advisable to contact us directly at: support@togonetworksltd.com.

Our Privacy Policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Website (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third party products and services. You are knowingly and voluntarily assuming all risks of using third party sites. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.

The Website is intended for use for any person over the age of 16 years old. The Company does not knowingly collect Personal Data from children under the age of 16 years old. We request that such individuals do not provide Personal Data through our Services nor access and browse the Website.

We may store or process your Personal Data in the EEA or in other countries. If you visit our Website or use our Services from locations outside of the EEA, please note that any information you provide to us through your use of our Website or Service may be transferred to and processed in countries other than the country from which you accessed our website. If you are a resident of the EEA we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

The website or our Services does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: https://allaboutdnt.com.

If you have any questions about these Terms, please contact us at:
support@togonetworksltd.com
Derech Begin 132, Tel Aviv, Israel