Privacy Policy
Last updated: March 25, 2024
Volumez provides data orchestration and block storage services through Volumez’s Software-as-a-Service platform (hereinafter, “Platform“) for Customers (collectively, “Services“).
This Privacy Policy (the “Privacy Policy” or “Policy”) describes the Personal Data (as defined below) that Volumez Technologies Ltd. and its affiliated companies, including Volumez Technologies Inc. (“Volumez”, “we”, “us”, “our”) collects, uses, processes, shares and stores the following categories of Personal Data:
- “Customer Data” means data (including Personal Data) provided or generated on the Platform that Volumez collects, processes and manages on behalf of and under the instruction of a legal entity with whom Volumez has signed an agreement for the provision of the Services (“Customers“).
- “User Data” means data (including Personal Data) concerning any individuals authorized by Customers to sign up, access and use the Platform that Volumez collects, processes and manages on behalf of and under the instruction of a Customer for the provision of the Services (collectively, “User”).
- “Business Contact Data” means data (including Personal Data) concerning any individuals acting on behalf of our Customers in respect of their engagement either directly with us or indirectly via a Marketplace (e.g., business contacts and authorized signatories on behalf of the Customer) (“Business Contact“).
- “Visitor Data” means data (including Personal Data) relating to visitors of the website https://volumez.com/technology/ (hereinafter the “Website“), who visit or otherwise interacts with our Website, or receives emails or communications under our control (collectively, “Visitor”, “you” or “your”).
Personal Data Obtained from Third-Party Sources. You may purchase our Services through independent marketplaces, such as AWS Marketplace (https://aws.amazon.com/marketplace) and Microsoft Azure Marketplace (https://azuremarketplace.microsoft.com/en-us/) (hereinafter, “Marketplaces“), and provide your Personal Data to those Marketplaces to access our Services. Please note that this Privacy Policy only applies to data (including Personal Data) that we (or third parties on our behalf) collect from or about you to provide the Services. We are not responsible for data (including Personal Data) processed by third parties, including such Marketplaces. These third parties have their own terms of use/terms and conditions and privacy policies, and you should read these carefully before you submit any Personal Data to these third parties. We do not endorse or otherwise accept any responsibility or liability for the Personal Data provided to such third-party websites.
Please note that we are not sharing Personal Data with the Marketplaces.
Please see our full Privacy Policy below in order to better understand our privacy and data protection practices in detail.
Please note that this Privacy Policy supplements our Terms of Use and our Website Cookie Policy.
This Privacy Policy is divided into the following sections:
Section 1 Data controller/data processor
Section 2 What Personal Data do we process about you and for which purposes?
Section 3 With whom do we share your Personal Data?
Section 4 How is your Personal Data transferred outside of the European Economic Area/ United Kingdom and Israel?
Section 5 How long do we store your Personal Data for?
Section 6 How do we keep your Personal Data secure?
Section 7 What rights do you have regarding your Personal Data?
Section 8 Does this Privacy Policy apply to third party links?
Section 9 Social Media Widgets
Section 10 What is our policy regarding minors?
Section 11 How do we approach changes to this Privacy Policy?
- DATA CONTROLLER/DATA PROCESSOR
The GDPR distinguishes between the data controller, who determines the purposes and means of processing; and the data processor, who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services and Website.
Volumez is the data controller of Business Contact Data and Visitor Data. With respect to such data, we assume the responsibilities of data controller, as set forth in this Privacy Policy.
When the Customer enters into a service agreement directly with Volumez, Volumez is the data processor of Customer Data and User Data, which we process on behalf of our Customer who is the data controller of such Personal Data. Accordingly, Volumez processes Customer Data and User Data strictly in accordance with our Customers’ reasonable instructions and as further stipulated in our agreement with the Customer.
Volumez may also function as a data controller of certain Customer Data, which is processed by Volumez for its own purposes (as described in Section 2.2 below), as an independent data controller.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at the Customer request, as well as all individuals whose Personal Data may be included in Customer Data processed through the Services, have been provided with adequate notices and given required consent to the processing of their Personal Data, where such consent is necessary, and that all legal requirements applicable to the collection, recording, use or other processing of Personal Data through our Services are fully met by the Customer, including specifically in the context of an employment relationship.
- WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU AND FOR WHICH PURPOSES?
When we use the term “Personal Data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual.- 2.1 Collection of Personal Data – General Provisions We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Data when you use the Website and the Platform, and the provision of it is solely based on your free will.
- 2.2 Personal Data Collected or Generated and PurposesWe will collect, generate and process the following categories of Personal Data through the Website and Services for the purposes identified below, and we will retain such Personal Data as identified in Section 5:
Categories of Personal Data Purposes of processing Examples of use Legal Basis – for EU Users only Visitor Data includes:
· identification data (i.e., first name, last name)
· contact details (i.e., work email address) and
· any other data related to your exchange with Volumez when you send an email (e.g., date and subject of your request, technical issues, CV, job position you are applying to, work experience, skills, etc.).
Managing requests · to answer your questions;
· to contact you if necessary;
· to review and analyze your job application;
· to organize an interview.
Legitimate interest of Volumez to manage its requests Pre-litigation or litigation management · to take action against any identified security breach;
· to manage any dispute or litigation;
· to seek advice from lawyers, auditors, and other professional advisers.
Legitimate interest of Volumez in defending its rights and interests Compliance with legal and regulatory obligations · to respond to law enforcement and governmental agency requests, to comply with applicable legal and regulatory requests and obligations (including investigations);
· to exercise legal and contractual rights, and initiate or respond to, or establish, exercise, and defend, legal and contractual rights claims.
Legal and regulatory obligations to which Volumez is subject Automatically-Collected Information
We automatically collect certain technical data when you visit and interact with our Website , including “device error messages” (dmesg) and “top” command. This data includes your IP address, browser type, operating system, the type of device you are using, device identifier, processes names. We will use cookies, beacons, tags, scripts and similar technologies in order to collect information regarding your use of the Website. This includes information such as page views, which URL you just came from, and which URL you go to next. This allows us to analyze trends, administer the Website, and collect demographic information. For more information, please see our Website Cookie Policy.
Improving the Website · to create aggregated statistical data, anonymized or pseudonymized data,
· to evaluate, develop, enhance, analyze and improve the Website;
· to facilitate your visit of the Website.
Legitimate interest of Volumez to improve its Website Supporting and enhancing our data security measures · to monitor, investigate bugs, and improve our Website;
· to prevent and mitigate the risks of fraud, error or any illegal, criminal or prohibited activity.
Legitimate interest of Volumez to secure its Website Pre-litigation or litigation management · to take action against any identified security breach;
· to manage any dispute or litigation;
· to seek advice from lawyers, auditors, and other professional advisers.
Legitimate interest of Volumez in defending its rights and interests Compliance with legal and regulatory obligations · to respond to law enforcement and governmental agency requests, to comply with applicable legal and regulatory requests and obligations (including investigations);
· to exercise legal and contractual rights, and initiate or respond to, or establish, exercise, and defend, legal and contractual rights claims.
Legal and regulatory obligations to which Volumez is subject Business Contact Data includes:
· identification data (i.e., first name, last name, country)
· contact details (i.e., work email address and phone number)
· professional details (i.e., workplace and job title)
Managing our Customer relationship · to liaise with the Customer’s representative on contracting and contract management and to manage the relationship;
· to invoice the purchase of our Services;
· to provide you with our Services.
Necessary for the performance of the contract concluded between Volumez and the Customer Pre-litigation or litigation management · to take action against any identified security breach;
· to manage any dispute or litigation;
· to seek advice from lawyers, auditors, and other professional advisers.
Legitimate interest of Volumez in defending its rights and interests Compliance with legal and regulatory obligations · to respond to law enforcement and governmental agency requests, to comply with applicable legal and regulatory requests and obligations (including investigations);
· to exercise legal and contractual rights, and initiate or respond to, or establish, exercise, and defend, legal and contractual rights claims.
Legal and regulatory obligations to which Volumez is subject User Data includes:
· identification data (i.e., first name, last name, country)
· contact details (i.e., work email address and phone number)
· professional details (i.e., workplace and job title); and
· Platform password
We process User Data as data processor to permit Customer’s end-users to sign up, access and use the Platform on behalf of the relevant Customers (as listed in Section 1). Therefore, Customers, as data controllers are responsible for determining the purposes. User Data that we process on behalf of our Customers (as listed in Section 1) is processed only on behalf of Customers. Therefore, Customers, as data controllers, are responsible for determining legal basis. Customer Data includes any Personal Data provided or generated on the Platform and contained in Customer Data processed on Customers’ behalf and under Customers’ instructions in accordance with our agreement(s) with each Customer. Customer may authorize us to use fully anonymized, de-identified and aggregated Customer for testing, development, improvement, security, controls, and operations of the Services and Platform, all in accordance with our agreement with each Customer. Legitimate interest of Volumez to improve and secure its Platform. Customer Data that we process as data processor on behalf of our Customers (as listed in Section 1) is processed only on behalf of Customers. Therefore, Customers, as data controllers are responsible for determining the purposes. Customer Data that we process on behalf of our Customers (as listed in Section 1) is processed only on behalf of Customers. Therefore, Customers, as data controllers are responsible for determining legal basis.
- WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
- 3.1 We will share your Personal Data with third-parties, as detailed below:
- 3.1.1 Service Providers and Subcontractors (including hosting, data security services, billing and payment processing services, fraud detection and prevention services, product analytics, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, content and data enrichment providers, insurers). We will share Personal Data to perform services on our behalf or complementary to our own, depending on each of their specific roles and purposes in facilitating and enhancing our Website and/or Platform.
- 3.1.2 Affiliates. We may share Personal Data with our affiliated companies and subsidiaries in order to provide joint services, for example, marketing, improving our services, etc. or when needed on a group basis, such as for risk management, insurance coverage, etc.
- 3.1.3 Governmental, Administrative or Judiciary Authorities. We may disclose Personal Data in case of a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
- 3.1.4 Lawyers and Interested Parties. We will share Personal Data in case of the management of possible disputes and other legal matters where appropriate.
- 3.1.5 Corporate Transactions. We may share Personal Data in connection with any proposed or actual reorganization, restructuration, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Volumez business, assets or stock (including in connection with any bankruptcy, insolvency or similar proceedings).
- 3.2 We will not sell or otherwise disclose Personal Data for monetary or other consideration to any third parties (and have not done so over the last twelve (12) months).
- 3.3 We will not share your Personal Data for cross-contextual behavioral advertising (and have not done so over the last twelve (12) months).
- 3.1 We will share your Personal Data with third-parties, as detailed below:
- HOW IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE OF THE ECONOMIC AREA/UNITED KINGDOM AND ISRAEL?
Due to our global business operation, we may store or process your Personal Data in several jurisdictions other than the country of your jurisdiction, including, for example in Israel, the UK, EU, US or in other countries (whether directly or through the use of our service providers). In some jurisdictions, the level of protection of your Personal Data may be lower than in the country of your jurisdiction.
- 4.1 How is your Personal Data Transferred Outside of Israel?
When we transfer Personal Data from the State of Israel to a third country outside Israel, the transfer takes place on the basis of:
- to a country declared as offering equivalent level of protection by the Israeli Privacy Protection Authority; or
- otherwise, based on your consent to transfer your Personal Data to other jurisdictions, understanding that in some countries the level of protection may be lower than the level under Israeli law.
- 4.2 How is your Personal Data Transferred Outside of the European Economic Area (“EEA”)/United Kingdom (“UK”)?
When we transfer Personal Data from within the EEA/UK to countries or international organizations that are based outside the EEA/UK, the transfer takes place on the basis of:
- an adequacy decision by the European Commission or the Information Commissioner’s Office (“ICO”), as applicable; or
- in the absence of an adequacy decision other legally permitted safeguards such as standard contractual clauses (“SCCs”) for the transfer of Personal Data to third countries or UK addendum, as applicable and supplementary measures, if required.
- 4.1 How is your Personal Data Transferred Outside of Israel?
- HOW LONG DO WE STORE YOUR PERSONAL DATA FOR?
We retain Personal Data for as long as we deem it as reasonably necessary in order to maintain our relationship and provide you with our Website and Services, as required by applicable laws and/or to fulfill our legitimate interests, all in accordance with our data retention policy.
Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal requirements, or (ii) for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or (iii) if we reasonably believe there is a prospect of litigation. Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for a particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.
Customer Data and User Data that we process on behalf of our Customers (as listed in Section 1) is processed only on behalf of Customers. Therefore, Customers, as data controllers are responsible for determining the retention period. Therefore, we will process the Personal Data under their instruction and will delete it from the Platform in accordance with our agreement with such Customer.
- HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
Volumez has implemented technical and organizational measures compliant with and industry standards to protect Personal Data, in particular against potential data breaches, either by accident or unlawfully, and against the destruction, loss, modification, unauthorized access or divulgation. However, we do not promise or guarantee that any Personal Data will be absolutely protected from unauthorized disclosure or use.
We restrict (and require our service providers to restrict) access to Personal Data to personnel on a “need to know” basis to facilitate the operation of the Website and/or provide our Services.
If you have found a vulnerability or would like to report a security incident, you may send an email to privacy@volumez.com
- WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL DATA?
- 7.1 General Provisions
Individuals have certain rights concerning their Personal Data, depending on their jurisdiction. If you wish to exercise your rights, you may contact us at: privacy@volumez.com. We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable laws).
When you ask us to exercise any of your rights under this Privacy Policy and the applicable laws, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data which is related to others that you are not authorized to receive, and to ask you questions to better understand the nature and scope of Personal Data that you request to access.
We may redact from the Personal Data we will make available to you any Personal Data related to others.
- 7.2 Data Rights for Israeli Data Subjects
If you are based in Israel, you are entitled to request us to:
- review and access your Personal Data that we process;
- update, amendment, and deletion of Personal Data which is incomplete, incorrect, outdated or unclear.
- 7.3 Data Right for EEA/UK Data Subjects
If you are based in the EEA/UK, you are entitled to request us to:
- access your Personal Data in order to obtain clear, transparent and understandable information on how we process your Personal Data and on your rights (as provided in this Privacy Policy), as well as a copy of your Personal Data;
- rectify your Personal Data in case your Personal Data are obsolete, inaccurate or incomplete;
- object the processing of your Personal Data when the processing is based on Volumez’s legitimate interest. Volumez will no longer process your Personal Data unless Volumez demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g. legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims;
- in certain circumstances under applicable laws, restrict the processing of some of your Personal Data during a limited period of time;
- withdraw your consentwhen it has been obtained and processing is based on consent;
- in certain circumstances under applicable laws, request data portability, meaning that you can receive the Personal Data originally provided by you in a structured and commonly used format or that you can request the transfer of the Personal Data provided by you to another data controller;
- in certain circumstances under applicable laws, delete your Personal Data (also known as the right to be forgotten);
- submit a complaint to your national data protection authority. If you have a complaint about how we use your Personal Data, we would always prefer you to contact us first. However, you may also make a complaint to your local data protection authority in the EEA/UK. If you are unsure which data protection authority to contact, please contact us at privacy@volumez.com
- 7.4 Data Rights for California Residents
- 7.4.1 Rights under CCPA/CPRA. If you are a California resident, you are entitled to request us to:
- access certain Personal Data we collected and used over the past 12 months, including the categories of Personal Data, the sources from and purposes for which we collect it, and the types of recipients to which we disclose it, and to request a copy of the specific pieces of Personal Data that we maintain about you;
- correct Personal Data that is inaccurate;
- subject to certain exceptions, delete the Personal Data that we have collected about you;
- opt-out of “sales” or “sharing” of your Personal Data to third parties.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Data. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
- 7.4.2 Non-Discrimination. California consumers have the right not to be subject to discriminatory treatment by Volumez for exercising their data rights described in section 7.4.1 above, and Volumez will not discriminate on that basis.
- 7.4.3 Right to Information About Disclosures of Personal Data for Direct Marketing Purposes. Under applicable law, California consumers can request information from us about whether we have disclosed Personal Data to any third parties for the third parties’ direct marketing purposes. We will not sell your Personal Data with, or disclose it to, third-party companies for their direct marketing purposes without your consent.
- 7.4.1 Rights under CCPA/CPRA. If you are a California resident, you are entitled to request us to:
- 7.5 Customer Data and User Data Provisions
Customer Data and User Data that we process on behalf of our Customers (as listed in Section 1) is processed only on behalf of Customers. Therefore, Customers, as data controllers are responsible for responding to your requests to exercise your rights. If you send your request to us, we will transfer it to the relevant Customer, in accordance with our agreement with such Customer.
You may also send your request to exercise your rights directly to the relevant Customer.
- 7.1 General Provisions
- DOES THIS PRIVACY POLICY APPLY TO THIRD PARTY LINKS?
You may, during your use of the Website, access links to or other websites operated by third parties outside of Volumez. Please note that this Privacy Policy only applies to Personal Data that we (or third parties on our behalf) collect from or about you and we cannot be responsible for Personal Data collected and stored by third parties, including the Marketplaces or any other marketplace. Third party websites and services have their own terms of use and privacy policies, and you should read these carefully before you submit any Personal Data to these websites or services. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or privacy policies.
- SOCIAL MEDIA WIDGETS
Our Website may include social media features, such as the LinkedIn™ button. These features will collect your IP address and which page you are visiting on our Website. They will also set a cookie to enable the feature to function properly. Social media features are hosted by a third party. Your interactions with these features are governed by the privacy policy of the company, social media platform or third-party service, providing it.
- WHAT IS OUR POLICY REGARDING MINORS?
The Website and Services are not intended for use by minors (an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly collect and process Personal Data relating to minors. If these age requirements are not met, you are required to avoid using the Website and/or Services. We will discard any Personal Data we receive from a minor immediately upon discovering that such a user shared Personal Data with us.
- HOW DO WE APPROACH CHANGES TO THIS PRIVACY POLICY?
We will change this Privacy Policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, if we have your e-mail address, we may also notify you by email of any material changes. The effective date of any change of Privacy Policy will be clearly marked on the top of each new Privacy Policy posted. We strongly encourage you to review this Policy periodically to ensure that you understand our most updated privacy practices.
- HOW TO CONTACT US
If you have questions, concerns or comments regarding this Privacy Policy or the data protection practices in connection with the Website and the Platform, please contact us at: privacy@volumez.com