Headlight Labs, Inc. and its affiliates (collectively “Headlight“, “Company” “we” or “us“) respect the privacy of its users (“User(s)” or “you“), and are committed to protect the personal information that you share with us in connection with the use of the Services (as defined in the TOU). This Privacy Policy (the “Privacy Policy“) is intended to describe our practices regarding the information we may collect from you when you use the Services, the manners in which we may use such information, and the options and rights available to you.

BY ENTERING, CONNECTING TO, ACCESSING AND/OR USING THE SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY“), IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE SERVICES.

2. Which information we may collect on our Users?

We may collect two types of data and information from our Users:

a.   The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from which we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information which is available to us while Users are using the Site. Non-personal Information which is being gathered consists of technical information and behavioral information.

b. The second type of information is individually identifiable information (“Personal Information“). This information may identify an individual or may be of a private and/or sensitive nature. Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User. The Personal Information is collected from the details the Users provide when Users wish to contact us or register to the Site which requires among others: name, e-mail address, company, job title, country and phone number.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of the Terms of Use and the Privacy Policy.

3. How Do We Collect Information on Our Users?

There are two main methods we use:

  • Use of the Services. We collect Non-Personal and Personal Information when you access or use the Services. In other words, we are aware of your usage of the Services and may gather, collect and record the information relating to such usage. We also collect Non-Personal and Personal Information derived from information we receive from third party services and providers we work with.

Voluntarily Provided. We may collect Personal Information which you voluntarily provide when you use the Services. We may also collect Non-Personal Information through the processing, analysis and anonymization of Personal Information provided by you.

  • In addition, we may publish open positions in the Company via its website or social media pages. In connection with this opportunity, we collect information that is provided to us by the job candidates (“Candidates“), when they apply to any of the open positions published by us, by e-mail, or otherwise.

We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

  • With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to provide you with personalized content and ads through the use of cookies;
  • When Performing our Services under the TOU: We collect and process your Personal Information in order to provide you with the Service, following your acceptance of this Terms; 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.
  • Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; Enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Use

5. What are the Purposes of the Collection of Information

We may use information that we collect about you for the following purposes:

  • To provide and improve our Services 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 to you marketing and advertising material and general and personalized content and advertisement via the Services, email, postal mail, telephone and/or mobile devices;
  • To develop, display, and track content and advertising tailored to your interests on our Service and other sites, including providing our advertisements to you when you visit other sites;
  • To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our Website and provide related services;
  • 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.

Headlight Labs, Inc. LLC will not share any Personal Information it collects with any third party unless authorized by You including as part of the use of the Services, or under this Privacy Policy. Headlight Labs, Inc. LLC may also disclose Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s support requests; (e) respond to claims that any content available on the Site violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) when Headlight Labs, Inc. LLC is undergoing any change in control, including by means of merger, acquisition or purchase or sale of all or substantially all of its assets; or (i) to collect, hold and/or manage your Personal Information through Headlight Labs, Inc. LLC’s authorized third party service providers, as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) cooperate with third parties for the purpose of enhancing the Services.

For avoidance of doubt, Headlight Labs, Inc. LLC may transfer and disclose to third parties, or otherwise use, Non-personal Information at its own discretion.

6. Sharing Information with Third Parties

  • 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.,WP Engine), data analytics services (e.g. Google Analytics), customer relationship management platforms (e.g.HubSpot, Salesforce), e-mail and text message distribution and monitoring services (e.g. MailChimp), dispute resolution providers, customer support and call center services (e.g. Intercom), session replay records for analytic purposes such as crashes, functionality and usability (e.g. Hotjar) 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 recipient’s or user’s undertaking of confidentiality obligations, and the prevention of any independent right to use this data except as required to help us provide the Services. We are remained responsible and liable for any Personal Information processing done by Third Party Service Provider on its behalf, except for events outside of its reasonable control.
  • 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 the rights, property or personal safety of our Company, any of our Users, or any members of the general public.
  • Our Affiliated Companies: We may share Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. In addition, should we or any of our affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our website or Services.

For the removal of doubt, we may share your Personal Information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use non-personal information in our sole discretion and without the need for further approval.

7. Non-Personal of Third Parties (“Customer Data”)

Without derogating from Your obligation to ensure that Customer Data does not include Personal Data of any third party, in the event such Customer Data does include Personal Data, you warrant to Headlight Labs, Inc. LLC that Customer Data has been and will be collected, processed and provided to Headlight Labs, Inc. LLC in accordance with applicable laws including laws on the protection of data subjects with regard to the processing of personal data and on the free movement of such data (collectively, “Data Protection Laws“)

If a third party makes a claim against Headlight Labs, Inc. LLC resulting from your failure to comply with this Privacy Policy, you will indemnify and hold Headlight Labs, Inc. LLC harmless with respect to any and all damages awarded by the court to the third party provided Headlight Labs, Inc. LLC do the following: (i) notify you as soon as reasonably practicable (or as required by applicable law); (ii) give you sole control of the defense and any settlement negotiations; and (iii) gives you the information, authority, and assistance you reasonably needs to defend against or settle the claim.

8.  Where Do We Store Personal Information?

Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in the Unites States and Israel, and as necessary, in secured cloud storage, provided by our third party service provider.

While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your Personal Information on the our behalf are each committed to keep it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

You hereby accept the place of storage and the transfer of information as described above.

9.  Using Cookies And Other Tracking Technologies

We use certain monitoring and tracking technologies, including ones offered by third party service providers. These technologies are used in order to maintain, provide and improve our website on an ongoing basis, and in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of our Users’ preferences and authenticated sessions, (ii) secure our website by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our website, (iv) create and monitor analytics, and (v) deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests and track ad performance (For more information about this practice, click here: http://www.aboutads.info/choices/).

10.  Direct Marketing

You hereby agree that we may use your contact details provided during the filling of a contact form or otherwise made available to us, 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: contact@headlight.co or by pressing the “Unsubscribe” button in the mail.

Please note that the Company may also contact you with important information regarding our Website. For example, we may notify you (through any of the means available to us) of changes or updates to our Website, payment issues, service maintenance, etc. You will not be able to opt-out of receive such service messages.

11. Job Candidates

The Company welcomes all qualified Candidates to apply to any of the open positions posted on our website or social media pages, by sending us their contact details and CV (“contact@headlight.co”). We are committed to keep Candidates’ Information private and use it solely for our internal recruitment purposes (including for identifying Candidates, evaluating their applications, making hiring and employment decisions, and contacting Candidates by phone or in writing).

Please note that the Company may retain Candidates Information submitted to it even after the applied position has been filled or closed. This is done so we could re-consider Candidates for other positions and opportunities at the Company; so we could use their Candidates Information as reference for future applications submitted by them; and in case the Candidate is hired, for additional employment and business purposes related to their work.

If you previously submitted your Candidates Information to the Company, and now wish to access it, update it or have it deleted from our systems, please contact us at: contact@headlight.co

12. Minors

To use the Services, you must be over the age of sixteen (16). Headlight Labs, Inc. LLC 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 thirteen (13) are not using the Services.

13. Security

We employ industry standard procedures and policies to ensure the safety of its Users’ Personal Information, reduce the risks stemming from loss of

information and prevent unauthorized use of any such information.  However, no measure can provide absolute information security.

14. Data Retention

We retain the Personal Information we collect only for as long as needed in order to provide you with our services and to comply with applicable laws and regulations. We then either delete from our systems or anonymize it without further notice to you.

If you withdraw your consent to us processing your Personal Information, we will delete your Personal Information from our systems (except to the extent 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).

15. 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 the limitations in 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 whose accuracy 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 (excluding data we obtained from other sources) 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, contact us at: contact@headlight.co. 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

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.

16. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Services and any information collected therein. Headlight Labs, Inc. LLC reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the Site and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

17. General Information

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the United States of America, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in California, United States of America.

This Privacy Policy was written in English, and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

18. Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: contact@headlight.co and we will make an effort to reply within a reasonable timeframe.