Last Revised: July 23, 2020
Reveal Com Ltd. (“Reveal”, “we” or “us”) respects the privacy of the users of our Solution (as defined below) including those users who were designated by our subscribers as employees or personnel who have been authorized to use the Solution on their behalf, (the “Authorized Personnel”), our subscribers’ customers or clients (the “Subscriber Customers”), and of the users of our website located at: https://www.f2f.ai/ (a “Visitors” and the “Site”, respectively). We are committed to protect the personal information of Visitors, Subscriber Customers and Authorized Personnel (each and together “you” or “User”) which we process in connection with the use of our Site and Solution (as defined below), as applicable (collectively – the “Services”).
Reveal provides organizations (“Subscribers”) an in-person interaction video and/or voice recording and analytics solution, via desktop and mobile applications (the “App(s)” and together the “Solution”) and other associated products and services.STATED SIMPLY, YOU SHOULD BE AWARE THAT IN ACCORDANCE WITH THE CONFIGURATION AND CHOICES MADE BY THE SUBSCRIBER (WHO MAY BE THE ORGANIZATION YOU WORK FOR, ENGAGED BY OR YOUR SERVICE PROVIDER) YOUR IN-PERSON INTERACTIONS WITH CUSTOMERS, USERS OR OTHER PERSONNEL OF SUCH SUBSCRIBERS MAY BE RECORDED AND DOCUMENTED BY AND VIA THE SOLUTION. REVEAL MERELY PROCESSES THE IN-PERSON INTERACTIONS INFORMATION (INCLUDING PERSONAL DATA INCLUDED THEREIN) ON BEHALF OF OR IN ACCORDANCE WITH THE INSTRUCTIONS OF THE SUBSCRIBER. THE SUBSCRIBER (NOT REVEAL) IS RESPONSIBLE FOR PROVIDING YOU, AS WELL AS ALL OTHER PARTICIPANTS OF THE APPLICABLE IN-PERSON INTERACTION – WITH ALL LEGAL NECESSARY AND APPROPRIATE DISCLOSURES AND NOTICES IN CONNECTION WITH THE SUBSCRIBERS USE OF THE SOLUTION (INCLUDING SPECIFICALLY THE VIDEO AND/OR VOICE RECORDING). IF FOR ANY REASON YOU FEEL THAT YOUR RECORDING WAS OBTAINED IN A MANNER NOT CONSISTENT WITH THIS AGREEMENT AND/OR ANY LAWS YOU ARE ENCOURAGED TO CONTACT THE SUBSCRIBER WITH WHOM YOU INTERACT.
Your Consent (PLEASE READ CAREFULLY!)
Please note: you are not obligated by law to provide us with any Personal Information.
What Information Do We Collect?
- First – What is Personal Information?
Personal Information is individually identifiable information, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or related to an individual or may be of private or sensitive nature information relating to an identified or identifiable natural person. Identification of an individual also includes association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc.
Personal Information does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person.
- Different Data Subjects
As reflected above we consider three types of Users (data-subjects) with respect to whom we process personal information: Visitors, Authorized Personnel, and Subscriber Customers. The scope, types and nature of personal information we may process in relation to each of these Users-types is different. For example, we process very little personal information of Visitors to our Site. On the other hand, since the core of our Services is all about record-taking of in-person interactions of Authorized Personnel with other individuals, this requires us to process a greater amount of personal information in relation to such Authorized Personnel.
- Authorized Personnel Data
We collect and process the following categories of personal information in relation to Authorized Personnel:
- Data Authorized Personnel actively provide us such as any entries, input text, uploaded data or actions in our Solution and App, for example:
- Authorized Personnel’s contact information,
- Authorized Personnel’s association/employment/affiliation with Subscriber, including subordinates and superiors.
- Authorized Personnel’s Solution and system preferences.
- The contents of your interaction with Subscriber Customers, which may include text/video/audio recording and transcripts of such communications.
- The contents of your interaction with our customer support, which may include text/video/audio recording and transcripts of such communications
- Authorized Personnel’s system data such as device model/type, web browser version, screen resolution, operating system, geolocation (for mobile Apps), etc.
- Authorized Personnel’s Solution and App session data, such as IP address, Authorized Personnel’s click-stream, preferred language, duration of session, time and date of session, session replay and session heatmaps, etc.
- Subscriber Customers Data
We collect and process the following categories of personal information in relation to Subscriber Customers:
- Data we are actively provided with by Authorized Personnel via the Solution and Apps in connection with the provision of Subscriber services, such as any entries, input text, uploaded data, or actions, for example:
- Subscriber Customer’s contact information,
- Subscriber Customer’s account information with respect to the services or products purchased from or the account maintained with the Subscriber.
- The contents of your interaction with Subscriber’s Authorized Personnel, which may include text/video/audio recording and transcripts of such communications.
- Visitors Data
We collect and process the following categories of personal information in relation to Visitors of our Site:
- Data Visitors actively provide us, such as in an email you may send us to our email address as listed on our Site, or any entries and text in our Site forms, for example, to our “contact us” form, or “request a demo” form.
- Visitors’ system data such as device model/type, web browser version, screen resolution, operating system etc.
- Visitors’ browsing session data such as IP address, information we derive from Visitors’ IP address such as city and country associated with the IP address, Visitors’ click-stream, HTTP referral, preferred language, duration of session, time and date of session, session replay and session heatmaps, etc.
- The contents of your interaction with our customer support or sales departments, which may include text/video/audio recording and transcripts of such communications
- Audio/Video Recording Notice
- As part the core functionality of the Solution we enable the video and/or voice recording of in-person interactions. Such recordings, by nature, may capture the voice, image, communication and information, of third parties participating in such interaction (whether actively or otherwise). You warrant and represent that prior to the use of the Solution all disclosures necessary or advisable under applicable law have been made to all individuals participating and/or in the vicinity of such recorded in-person interaction, and all consents and approvals for the recording as necessary or advisable under applicable law, have been obtained.
PLEASE NOTE THAT THE AFOREMENTIONED DISCLOSURE AND CONSENT REQUIREMENTS WITH RESPECT TO RECORDINGS OF IN-PERSON INTERACTION MAY VARY FROM STATE TO STATE, AND COUNTRY TO COUNTRY. YOU REPRESENT, COVENANT, AND WARRANT THAT (I) YOU WILL REVIEW ALL APPLICABLE LAWS, AND TO THE EXTENT REQUIRED, OBTAIN SUCH NEEDED LEGAL COUNSEL BEFORE YOU USE OR ALLOW OTHERS TO USE THE SOLUTION; AND (II) YOUR USE OF THE SOLUTION DOES NOT BREACH OR INFRINGE ON THE RIGHTS OF ANY THIRD PARTY, INCLUDING THE RIGHT FOR PRIVACY. YOU ARE SOLELY RESPONSIBLE FOR COMPLYING WITH ANY AND ALL APPLICABLE LAWS IN CONNECTION WITH YOUR USE OF THE SOLUTION.
How Do We Collect Personal Information?
There are three main ways in which we collect Personal Information: (i) information is actively provided to us by the Subscriber or its Authorized Personnel, (ii) information is collected as part of the core recording functionality of the Solution and otherwise is derived automatically by our systems from Authorized Personnel’s use of our Solution, Services and Apps, (iii) information we obtain from other sources or third parties.
- Actively provided information
Generally, this category refers to any information, data or content you actively create, input or provide through our Solution, Services or Apps.
- Automatically collected information
This category refers to personal information automatically collected from User’s use and interaction with the Solution, Services or Apps. We collect information about your interaction with our Solution and Apps, in certain cases about your impressions of and reactions to our communication with you (including newsletters and informational materials about our Services and Solution which you agreed to receive from us). This is information we receive from devices (including mobile devices) and software you use when you access our Solution or Apps.
For more information about our use of these technologies and how to control them, see our cookies policy www.reveal-labs.com/cookies_policy
- The settings and activation of the recording functionality of the Solution is configured by the Subscriber, selecting whether such feature is activated in connection with designated business hours, calendar events, other criteria, or actively initiated or disabled by Authorized Personnel each time it is used to record an in-person interaction. For more information regarding the activation settings of the recording functionality of the Solution, contact the Subscriber (which is an organization employing or engaging you). Information obtained from third Parties
We may also collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information or that you have freely and publicly provided. For example, if you are an Authorized Personnel we will probably be receiving certain information relating to you from the Subscriber (which is an organization employing or engaging you) in order to provide such Subscriber with our Services, e.g., so that we can configure and set up Authorized Personnel login credentials for our Solution prior to such Authorized Personnel’s first login.
What are the Purposes of the Collection and Processing of Personal Information?
- Legal Basis for collection and Processing
- With respect to Authorized Personnel and Subscriber Customers
- For the performance of a contract – We collect and process your Personal Information as necessary for the establishment and performance of our contractual engagements with our Subscriber (who is your employer or service provider, respectively), in the scope of our role as services providers (processors) to Subscriber and under such Subscriber’s instructions. Under such engagement we shall provide Subscriber with the Services, maintain and improve our Services, Solution and Apps, develop new services and features for our Users and Subscribers, and personalize the Services in order for Users to get a better user experience.
- Consent– We ask for your consent to process certain portions of your information for specific purposes, and you have the right to withdraw your consent at any time.
- With respect to Visitors
- For the performance of a contract and provision of services – following your acceptance of these Terms, we collect and process your personal information in order to provide you with our Site; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Services in order for you to get a better user experience.
- Why Do We Use Your Personal Information?
We may use information that we collect about you, for different purposes, which may vary accordingly if you are a Visitor, Authorized Personnel, or Subscriber Customer.
- To provide and improve our Services, Solution, 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 display or send you marketing and advertising material and general and personalized content and advertisement;
- To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal or anonymized, in which we and/or our business partners might make use of in order to operate and improve our Site, Solution and Apps;
- 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.
Sharing Information with Third Parties
Reveal may share your Personal Information with third parties (or otherwise allow them access to it) in a manner and scope which may vary accordingly if you are a Visitor, Authorized Personnel or Subscriber Customer, and only in the following instances:
- Subscriber: We will share certain data concerning Authorized Personnel or Subscriber Customer with the Subscriber (their employer or service provider, as applicable) as required in the scope of provision of Services to such Subscriber.
- Third Party Services: We are partnering with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services (e.g., AWS, Google Cloud, and Azure), data analytics services (e.g. Google Analytics), customer relationship management solutions and recording platforms (e.g. NICE), data and cyber security services, fraud detection and prevention services, e-mail and text message distribution and monitoring services, payment processors dispute resolution providers, customer support and call center services, session replay records for app analytic purposes such as crashes, functionality and usability, remote access services, and our business, legal and financial advisors (collectively, “Third Party Service Providers“).
Such Third Party Service Providers may receive or otherwise have access to your Personal Information, depending on each of their particular roles and purposes in facilitating and enhancing the Services, and may only use your Personal Information for such purposes. Such disclosure or access is strictly subject to the undertaking of confidentiality obligations, and the prevention of any independent right to use this information except as required to help us provide the Services. We remain responsible and liable for any personal information processing done by Third Party Service Providers on our behalf, except for events outside of our reasonable control and except for such Third Party Service Providers with whom you have a direct contractual relationship.
- Other Users: if you are an Authorized Personnel or Subscriber Customer, our Services may automatically share personal information with the Subscriber or select Authorized Personnel to the extent that, and in the manner configured by the Subscriber on the Solution. Therefore, you are required to take into consideration that the use of certain functionality or of input fields, available on the Solution, may be accessible to other Authorized Personnel.
- Law Enforcement, Legal Proceedings, and as Authorized by Law: We may disclose or otherwise allow access to personal information pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
- Protecting Rights and Safety: We may share your personal information with others, with or without notice to you, if we believe in good faith that this will help protect our rights, property or personal safety, any of our Users, or any members of the general public.
For the removal of doubt, we may transfer, share or otherwise use non-personal information in our sole discretion and without the need for further approval.
Where Do We Store User’s Personal Information?
Information regarding the Users may be maintained, processed and stored by us and our authorized affiliates and service providers in jurisdictions other than the jurisdiction of your residence or location, as necessary in secured cloud storage, provided by our Third Party Service Providers.
For more information regarding the place of storage and the transfer of information as described above, please contact us at Privacy@reveal-labs.com.
Using Cookies and Other Tracking Technologies
- We use certain monitoring and tracking technologies, including ones offered by third party service providers in order to collect and process certain portions of the personal information we specified above. These technologies are used in order to maintain, provide and improve our Solution and Services on an ongoing basis, in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of and apply our Users’ Services and Site preferences and authenticated sessions, (ii) better secure our Solution by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Solution and Services, (iv) monitor and analyze our ads’ performance (v) create and monitor analytics relating to use of our Solution and Services, and (v) deliver to you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests.
- Cookies: A cookie is a small data file that is downloaded and stored on your computer or mobile device when you visit our Website. Learn more about cookies here: www.allaboutcookies.org
- Learn more about your choices and how to opt-out of tracking technologies:
You hereby agree that we may use Visitors contact details provided during the filling of a contact form on our Site, for the purpose of informing you regarding our products and services which may interest you, and to send to you other marketing material. You may withdraw your consent via sending us written notice by email to the following address: Privacy@reveal-labs.com or by pressing the “Unsubscribe” button in the mail.
Please note that we may also contact Users with important information regarding our Solution, Services or Site. For example, we may notify you (through any of the means available to us) of changes or updates to our Solution, Services or Site, payment issues, service maintenance, etc. You will not be able to opt-out of receipt of such service messages.
To use the Services or Solution, you must be over the age of sixteen (16). Reveal does not knowingly collect personal information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services or Solution. In the event that it comes to our knowledge that a person under the age of sixteen (16) is using the Services or Solution, we will prohibit and block such User from accessing the Services or Solution and will make all efforts to promptly delete any personal information stored with us with regard to such User.
We take a great care in implementing and maintaining the security of the Services and Solution, and the User’s personal information. The personal information is hosted on Amazon Web Services, or upon request by the Subscriber, on Google Cloud, or MS-Azure, which provides advanced security features. Reveal employs industry standard procedures and policies to ensure the safety of its Users’ personal information and prevent unauthorized use of any such information. Among other means we use Secure Socket Layer (SSL) technology, which creates an encrypted link between our web server and your browser, and provides a secured path of communication to ensure the information remains protected and private.
Please note however, that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any personal information.
We may retain your personal information for as long as legitimate and to the extent required for the achievement of the purposes listed under Section 4, in accordance with the instructions of our Subscribers who are the Controllers of the personal data we collect and/or process. This includes without limitation, as reasonably necessary to comply with our legal obligations and/or protect our legitimate interests, and with respect to data used for marketing activity, for as long as we have Visitor’s consent therefor. We then either delete such personal information from our systems or anonymize it without further notice to you.
User Rights – Updating, Obtaining a Copy of, or Deleting Your Personal Information
- If the law applicable to you grants you such rights, you may ask to access, correct, or delete your personal information that is stored in our systems. You may also ask for our confirmation as to whether or not we process your personal information.
- Subject to limitations of law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any personal information the accuracy of which you contest while we verify the status of that data.
- Subject the limitations in law, you may also be entitled to obtain the Personal Information you directly provided us in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party.
- If you wish to exercise any of these rights or withdraw your consent, please contact us at: Privacy@reveal-labs.com. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your personal information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates, or as we are otherwise permitted under any law applicable to you.
- To find out whether these rights apply to you and on any other privacy related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.
- Authorized Personnel and Subscriber Customers
As above stated, Reveal collects and processes your personal information as a processor (as defined under applicable data protection laws and regulations), in the scope of services provided by Reveal to a Subscriber which is the employer of Authorized Personnel and service provider of Subscriber Customers, and in accordance with such Subscriber’ instructions. Therefore, Authorized Personnel and Subscriber Customers may only contact Subscriber with any request to exert their rights, claims or inquires with respect to any of their personal information, which has been collected and processed hereunder.
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