Privacy Policy

The Savvy Privacy Policy was last updated on November 5, 2020


Your privacy is important to us, and we are committed to making our practices regarding your personal data more transparent and fairer. This Privacy Policy ("Policy") explains how we, Scalez Ltd., company no. 515975381 ("Savvy", "we", "us" or “our”), with registered place of business at Habarzel 1, Tel Aviv, Israel and our corporate affiliates,  collect and process your personal data when you ("you" or "your", the user of our Services) access and use our website (www.savvy.style) (the "Site") and the services available on our website, mobile website, application, facebook messenger, application related features, media channels, linked, or otherwise connected thereto or via third party’s channels, websites or applications or any other media form] (which, together, are referred to as the "Services"), and how we use such information and protect it. It is important that you read this privacy policy carefully so that you are fully aware of how and why we are using your data.  We also want to make sure that you are aware of the options available to you when you access and use our Services. 

You are not legally required to provide us with any Personal Data (defined below), but without it we may not be able to provide you with the full range of Services or with the best user experience when using our Services. To learn more about the choices available to you, please read Section ‎10 below.

Our Terms of Use require all account owners to be at least 18 years of age, therefore, this Policy does not discuss use of our Services by minors.

1. THE PERSONAL DATA WE COLLECT AND PROCESS:

We collect contact information, technical data, profile data, communication data, content, and other data received from you. We use this personal data to provide, improve and secure our Service; for analytics, marketing and sales purposes; to comply with applicable laws; and to support our legitimate interests.

We collect various types of data regarding our users as well as data regarding visitors to our Site (“Visitors”). Such data is typically collected and generated through the users’ interaction with us or our Service, through automatic means, directly from such Visitor or user, or from other third parties, including service providers. 

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, constitutes “Personal Data”), under the applicable lawful basis (in brackets), and use it for the following purposes:

 

  1. Information you provide us 

Your name and email address as well as a username and account password (contractual performance; legitimate interests; legal obligations; consent):

  • We need to know these to register you as a user, secure your account and to authenticate you when you log into your account in the future (contractual performance).
  • We need to know this information so that we can process any orders for Services that you make on our Site, send you email confirmations of your order,  and verify your payment details (contractual performance).
  • We also use your data for fraud prevention purposes (legitimate interests).
  • We need this information so that we can respond to your queries and occasional complaints (contractual performance; legitimate interests).
  • We may also keep a record of these to inform any future communication with us, to demonstrate how we communicated with you throughout, to ensure that we provide you with the best possible service.
  • Sometimes, we may need these details to send you communications that are required by law or necessary to inform you about our changes to the services we provide you (legal obligations; contractual performance).
  • If you actively consent to receiving newsletters, marketing and promotional information from us, we will also process your email address for the purpose of providing you with these (consent).

Social Media Profile information, when you sign up via Facebook or Google+: data from your public profile, including your name, profile photo, email address, nationality and other information is provided to us by Facebook or Google+ (contractual performance; legitimate interests; legal obligations; consent): We need to know these to register you as a user, secure your account and to enable you to log into your account in the future (contractual performance).

  • Savvy associates the email address provided by the social media provider with your account so that you can use your email address to sign in to your account in the future if you no longer wish to sign in using your social media account credentials.
  • If you do not want your information to be shared with us by the social media provider, then you can simply sign in to your Savvy account using your account credentials instead of your social media account credentials.

Your (mobile) telephone number

  • We ask for your phone number so that we can contact you in case we need to. (contractual performance) 

Your profile picture and other pictures (consent)

  • If you choose to add a profile picture to your account, we will display this picture to other users of the Services and to our Stylists. 
  • We also use your picture(s) to help our Stylists to provide personalized styling advise to you.

Your payment details (contractual performance, legitimate interests)

  • For online payments and other transactions, we use a third party payment service provider e.g. Recurly, Stripe Payments Europe Ltd., Paypal (each, “PSP”). We do not ourselves access any payment details from users of the Services. Processing of any of your personal data by the PSP is covered by the PSP’s respective privacy policy. 
  • In addition, we may use this data for fraud prevention and detection purposes. (legitimate interests).
  • we use this data to process your order, or to process refunds to you (contractual performance).]

Personal data that we collect when you use our styling services (contractual performance, consent):

  • When you interact with both our chat bot and our Stylists, we collect your gender, height, dress sizes, and, if relevant, cup size. We use this data to provide you with our styling services and to enable our Stylists to give you fashion related advise that is best suited to your needs (contractual performance). 
  • Some of this information might constitute sensitive information, in which case we are going to obtain your consent before collecting it (consent).

  1. Personal data that is processed when you communicate with us (contractual performance, legitimate interests, consent):
  • When you interact with our customer support representatives via email, telephone, bots, or online we collect and process personal data, such as your name, phone number, email address and contact. In addition, we process and store all information communicated by you with respect to your various sizes, looks, appearance and styling choices and preferences, as well as our notion, categorizing and analysis with respect to your personal style and preferences so we can provide you with service and support (contractual performance). 

  • We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue (legitimate interests). 
  • To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyse any feedback provided to us through voluntary customer surveys to make sure we continuously improve that customer service (legitimate interests). 
  • With your consent, our customer support representatives may sign in to your account, if appropriate, to help troubleshoot and resolve your issue (consent).

  1. Information automatically collected or generated from your use of the Services (by cookies, web beacons and similar technologies)

We use a tool called “Google Analytics”, provided by Google and used by us to track and analyze the use of our Services for internal purposes. To learn more about how Google uses data from our use of Google Analytics, we recommend you review Google’s policies located at: google.com/policies/privacy/partners. For additional information, please see Google Analytics’ opt-out web tool available at: https://tools.google.com/dlpage/gaoptout

When you interact with our Services, we may automatically collect (by cookies, web beacons and similar technologies) certain information: 

(a) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, geographic location of the device that you use to log in (consent; legitimate interests), language preferences, browser plug-in types and versions, operating system, Android or iOs Operating System Vendor (e.g. Galaxy, HTC, iPhone, etc.), version, device information, screen resolution. If you choose to save your password for automatic sign-in, we will also record your password in a cookie file; 

(b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, the frequency and scope of your use of the Services, page interaction information (such as scrolling, clicks, and mouse-overs), the content you viewed (including advertisements you clicked on) and pages you visited, your communications with Stylists, other users and third parties, and cookie data. 

We may also use tracking pixels in our email newsletter enabling us to see if and when an email was opened and if certain links in that email were clicked by the addressee (consent). This allows analysis, reporting and optimization of email marketing campaigns. You may withdraw your consent at any time through the “unsubscribe” link at the bottom of each of our marketing emails or by contacting

Information about your device and how you use our website (including your IP address, device type) (legitimate interests)

  • We use this data to continuously improve our website, to set default options for you, and to show you the correct content. We may also use it to develop, test and improve the systems, services and products we provide to you by recording your browser’s Session ID. This data is also used to prevent and detect fraud.
  • We also use this data to deliver relevant website content and advertisements to you (including suggestions and recommendations), to measure or understand the effectiveness of the advertising we serve to you, and to monetize our website;
  • We may perform market research or measure Website usage; and analyse traffic counts and website performance;
  • We also use this information to perform network communications, to administer our site and to support internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure, for maintaining and analysing the function of the Services' features and offerings, advertisements, and e-mail communications, and to improve them when necessary. 

  1. Any of your personal data (legal obligation)

There may be situations where we are legally required to share your personal data, for example, when a court order is submitted to share it with law enforcement agencies or a court of law.

  1. Anonymized or aggregated data

We may collect, use, and share anonymized or aggregated data such as statistical or demographic data for any purpose. Anonymized or aggregated data may be derived from your personal data but is not considered personal data, as this data does not relate to an identified or identifiable person. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. We may use anonymized or aggregated data indefinitely without further notice to you.

  1. If you fail to provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Savvy limits access to your personal information by Savvy personnel to those whom we believe reasonably need that information to provide products or services to you or in order to do their jobs.

  1. Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your further acknowledgment or consent, in compliance with the above rules, where this is required or permitted by law.

2. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We share your data with our affiliates; with our service providers and advisors; and in accordance with legal compliance.

We value your privacy and will not share your personal information except with the parties set out below for the purposes indicated in Section ‎1 above. We make sure they adhere to the same standards of data protection that we do.  

  • With our affiliates for the purposes described in this Privacy Policy. This relates to companies that are legally part of the same group of companies that we are part of, or that become part of that group. Currently our affiliates are based in Israel and the USA and provide IT and system administration services.
  • Stylists acting as processors, based in the USA, who provide Users with fashion and styling advise.
  • Service providers based in Israel and the USA who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based in Israel and the USA who provide consultancy, banking, legal, insurance and accounting services.
  • We may use and share with third parties the information we collect from and receive about you in order to deliver content or advertising; to perform market research or measure website usage; and to analyze traffic counts, your interests and website performance.
  • We may disclose Personal Information (i) as a response to a legal request (such as a court order, search warrant, or subpoena) if we believe that we are required to do so by applicable law; or (ii) when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud, intellectual property infringement, piracy, or other illegal activities; enforce this Policy or our Terms of Use, including in order to investigate potential breaches; protect our rights, property or safety, or those of our users or from members of the public from harm, as required or permitted by law; and prevent death or imminent bodily harm. In such events, Savvy may disclose a name, address, country, phone number, email address and company name.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Non-Personally Identifiable Information. 

  • We may also share aggregated or non-personally identifiable information that we collect under any of the above circumstances with our business partners, affiliates or other third parties to develop and deliver targeted advertising on our websites and on websites of third parties. We may also share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may disclose to our advertisers the number of visitors to our website and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find interesting and to customise content and advertising. 


3. COOKIES AND OUR COLLABORATION WITH THIRD-PARTY AD NETWORKS

We and our service providers use cookies and other technologies for performance, tracking, analytics and personalization purposes.

Our Site, Services and some of our service providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns. A “cookie” is a small text file that is used, for example, to collect data about activity on our Services. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the Visitor, Customer or End User. We recommend the use of cookies for an optimal user experience of our Services. 

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, if you refuse to accept cookies, you won't be able to access and take advantage of many features of our Services properly.

The types of cookies we use are set out below:

  1. Performance Cookies: This type of cookie helps us to secure and maintain our Service, and remembers your preferences for features on the Service such as language and currency preferences, so you don’t have to re-set them at every visit.
  2. Analytics Cookies: Every time someone visits our Service, the analytics services we use generate cookies which can tell us whether or not you have visited the Service in the past, and provide additional information regarding how users use our Service (such as where users tend to click on our Service, or how often they visit). Your browser will tell us if you have these cookies and, if you don’t, we generate new ones. 
  3. Registration Cookies: When you register and sign into our Services, we generate cookies that let us know whether you are signed in or not, and maintain your login session. While you are signed into our Services, we combine information from your Registration Cookies with Analytics Cookies, which we could use to learn, for example, which pages you have visited.
  4. Third Party Integration Cookies: Within our Service, third parties may also set their own cookies. They do this to track the performance of their applications that are integrated with our Service, or to customize their services for you. Because of how cookies work, we cannot access these cookies, nor can these third parties access the data in other cookies that we use on our Service.
  • Hotjar Cookie

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

  • Mixpanel Cookie

Our websites use cookies from Mixpanel to register your type of browser as well as your operating system, language preferences and IP address and to send these data to a Mixpanel server. We only receive your IP address in anonymised form from Mixpanel so that you can be assured that your privacy is always protected. Moreover, via the Mixpanel platform an analysis is made of all data registered during the use of our offers. In this way, we can continuously improve our offers to you. If you do not wish to accept this data registration, please change your browser settings accordingly. You can always reject Mixpanel’s registration and storage of these data by following the instructions at this link: https://mixpanel.com/optout/.

More information in English about Mixpanel and Mixpanel’s data protection policy is available at: https://mixpanel.com/privacy/.


  • Facebook Pixel

Our websites use Facebook Pixel provided by Facebook Inc. (“Facebook”) If you are redirected to our websites via an ad on Facebook or via Facebook Messenger, Facebook will set a cookie on your computer. This conversion-tracking cookie will be set when a user clicks an ad on Facebook. Such cookies expire after 28 days and cannot be used to identify you personally. If a user visits certain pages on our website before the cookie has expired, we and Facebook can see that the user clicked the ad and was redirected to this page. Each individual Facebook customer receives a different cookie, and therefore cookies cannot be tracked via the websites of Facebook customers. The data collected by way of conversion cookies are used to make conversion statistics for Facebook customers who have decided to use conversion tracking. The customers will receive information about the total number of users who have clicked their ad and been redirected to a page with a conversion-tracking tag. However, they will not receive any information that may be used to identify specific users.

If you do not want this tracking to take place, you can disable the installation of the cookie that is necessary for the tracking – for example in your browser settings where you can either deactivate the automatic cookie function or disable cookies from the “facebook.com” domain in your browser.

Google Ads and Other Advertising Networks

We collaborate with Google and other advertising networks as business partners. These third party networks use cookies to serve ads it displays on our Site and on other websites of its partners, based on a user's prior visits to our Site or other websites. When users visit a Google partner's website, a cookie may be dropped on that end user's browser. 

  • Google's use of advertising cookies enables it and its partners to serve ads to you based on you visit to our sites and/or other sites on the Internet.
  • You may opt out of personalised advertising by visiting Ads Settings. Alternatively, you can opt out of some third-party vendor's use of cookies for interest-based advertising by visiting aboutads.info.
  • [If you wish to prevent the use of your mobile device's advertising ID (e.g. for interest-based advertising), you may change your device settings to reset such advertising ID or to opt-out of such advertising (typically, this is available under the "Privacy" or "Ads" section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the "Settings" or "Help" section in your browser menu). 
  • If you are an End User who lives in the USA, Canada or Europe, you can also opt-out from the collection of your data by our Customers who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.youronlinechoices.com (for European users).
  • The third parties that display advertisements on our site may use tracking technologies, such as cookies, web beacons and similar technologies, to collect information about users who view or interact with their advertisements. Unless expressly stated otherwise, our website does not provide personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers end users a single location to opt out of ad targeting from member companies (www.networkadvertising.org).


4. COMMUNICATIONS 

We engage in service and promotional communications, through e-mail, phone, SMS and notifications. 

Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, service changes, log-in attempts or password reset notices, etc. You can control your communications and notifications settings from your Account settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices). 

Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms. 

If you do not wish to receive such promotional communications, you may notify Savvy at any time by sending an e-mail to [email protected], changing your communications preferences in your Account settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

5. TRANSFERS OF PERSONAL DATA

We store your data in Israel and in the United States. 

We are an Israeli private company headquartered in Tel Aviv, Israel. Please be aware that we may need to transfer your information, including your Personal Data, to Israel, the United States and other jurisdictions as necessary for the proper delivery of our Services through certain third parties that we use to operate and manage the  Site and Services, including [AWS / Google Cloud Storage / Microsoft Azure]. [ERM: Please confirm/indicate which cloud service you use]. 

DATA RETENTION

We retain your data for as long as necessary for the performance of our Service or for supporting and exercising our legitimate interests, and in accordance with our legal obligations.

Savvy will retain your information only for as long as is necessary for providing you our Services or for as long as your account is active, for satisfying any legal, accounting, or reporting requirements, or for the relevant term under the respective statute of limitation that may apply to the relationship between you and us. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you have any questions about our data retention policy, please contact us by email at [email protected].

6. HOW DO WE SECURE YOUR INFORMATION?

We secure your Personal Data using industry-standard administrative, technical, and physical measures.

We consider data security a top priority and we do our best to keep your Personal Data secure. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Such measures include:

  • Encrypting many of our services using SSL.
  • Employing firewalls and intrusion detection systems.
  • Practicing administrative, technical, and physical security procedures to help protect the information you provide us.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with personal data breach (whether such breach is actual or a probable threat) and will notify you and any applicable regulator of a breach where we are legally required to do so.

Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your personal information, we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. 

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contact Us" section above.

7. PROTECTION OF CHILDREN’S PRIVACY

Our Service is not directed towards children under the age of 18. 

Our Services are not directed to children under eighteen (18) years. We do not knowingly collect Personal Data from children and do not wish to do so.

If it comes to our attention through reliable means that a registered user is a child under eighteen (18) years of age, we will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at [email protected].

 

8. RIGHTS TO ACCESS PERSONAL DATA  

  • You have the right to request access to your Personal Data held by us. This enables you to receive a copy of the personal data we hold about you. Upon your request, we will verify that you are the person making this request and in order to do so, we may request identification documents from you.
  • You also have the right to request correction of your Personal Data held by us. We reserve the right to verify the accuracy of the new data you provide to us.

9. RIGHTS OF INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA

Individuals have certain rights concerning their Personal Data. You may exercise these rights by contacting us.

If you reside in the European Union, you have certain rights under European Data Protection Law with respect to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which, if applicable, will be notified to you at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, or to delete your account, please contact us under [email protected] 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you do not reside in the European Union but you believe that you have a right to restriction of processing or a right to object to processing under your local laws, please contact Savvy at [email protected]

10. RIGHTS OF CALIFORNIA RESIDENTS

We may collect personal information about California residents who are afforded additional rights under the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et seq. (the “CCPA“)). California residents have the right to request that Savvy (i) provide you with access to the Personal Information that we hold about you, (ii) correct your Personal Information, (iii) delete your Personal Data, and (iv) cease or restrict disclosures or sales of your Personal Data to third parties. You may request any of these by contacting us via email at [email protected] or by physical mail to: Scalez Ltd., 1 Habarzel st, Tel Aviv, Israel. Upon your request, we will verify that you are the person making this request and in order to do so, we may request identification documents from you.

You also have a right against discrimination for exercising any of these rights, which Savvy is committed to upholding and honoring.


We do not “Sell” (as defined in the CCPA) your personal information which we have collected or may collect and in the event we will Sell your personal information, we will notify you by updating this Privacy Policy in accordance with Section ‎14 and we will provide you with the option of opting out of such “sale”.

11. DATA CONTROLLER/PROCESSOR

We are the Data Controller of our site visitors’ and customers’ Personal Data; we are the Data Processor of any Personal Data contained in End User Data processed on behalf of our Customer. 

Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: 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, to the extent that such laws and regulations apply.


Savvy  is the “Data Controller” of its site visitors’ and customers’ Personal Data, and assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy.


12. CONTACT US  

You can contact us with any questions regarding privacy and data protection.

Our full details are:

Scalez Ltd.

Email address: [email protected]

Postal address: 1 Habarzel st. Tel Aviv Israel

Telephone number: +972506349716

If you are an EU resident, you have the right to make a complaint at any time to the relevant supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach such authority, so please contact us in the first instance.

13. CHANGES TO OUR PRIVACY POLICY

We may update this policy from time to time.

From time to time, we may make changes to this Privacy Policy in order to make sure that we are providing you with the most up-to-date information. The most current version of the policy will govern our use of your information and will always be at [add URL]. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within the Services. To the extent permitted by law, by continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy. Any changes to this privacy notice will apply to you and your data immediately.

14. ADDITIONAL NOTICES

If one provision of this policy is invalid, the rest of the policy remains valid.

If any provision of this Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect, provided, however, that in such event this Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

15. GOVERNING LAW AND JURISDICTION

Israeli law applies to this privacy policy.

This Policy shall be governed by the laws of the State of Israel, without respect to its conflict of laws principles. We each agree to submit to the personal and exclusive jurisdiction of the courts located in Tel Aviv, Israel, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.