In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Gramsoft Ltd. (together, “Brew” “we”, “our”or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:
We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” or “personal information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.
Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.
Table of contents:
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.
Finally, please note that some of the abovementioned personal data will be used for fraud detection and prevention, and for security purposes. The abovementioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
2.1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
2.2.Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookies policy.
In addition to the recipients described above, we may share your personal data as follows:
3.1. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
3.2.If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
3.3.In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
3.4.Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
If you want to receive the list of the current recipients of your personal data, please make your request by contacting us to info@getbrew.com.
4.1. Storage: We store our data in (i) AWS (North Virginia – US); (ii) Digital Ocean cloud services; (iii) Hubspot (CRM services); (iv) Make (Integration platform); (v) ClickUp (Project management) and (vi) Google cloud services such as Google Drive.
4.2.Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/lawtopic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
4.3.Internal transfers: Transfers within the Brew group will be covered by an internal processing agreement entered into by members of the Brew group (an intra-group agreement)which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
4.4.External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.
5.1. Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
5.1.1.You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
5.1.2.You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
5.1.3.You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
5.1.4.You have the right to object, to or to request restriction, of the processing;
5.1.5.You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;5.1.6.You have the right to object to profiling;
5.1.7.You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
5.1.8.You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
5.1.9.You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement)at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
You can exercise your rights by contacting us at info@getbrew.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
5.2.Deleting your account: Should you ever decide to delete your account, you may do so by emailing info@getbrew.com. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@getbrew.com.
We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service
We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.
9.1. Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
9.2. Mix panel. We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.
9.3. Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
9.4. LinkedIn Pixel. The LinkedIn Insight Tag is a piece of lightweight JavaScript code that we have added to our websites in order to enable in-depth campaign reporting and to help us unlock valuable insights about our Website visitors. We use the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about members interacting with our LinkedIn adverts. The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor’s browser until they delete the cookie or the cookie expires. You can opt out of cookies from LinkedIn on your LinkedIn settings page and we recommend that you read their Cookie Policy for more information.
9.5. Twitter Pixel. Functions of the Twitter service have been integrated into our Website and App. These features are offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. (“Twitter”) When you use Twitter and the “Retweet” function, the websites you visit are connected to your Twitter account and made known to other users. In doing so, data will also be transferred to Twitter. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by Twitter. We recommend that you read Twitter’s privacy policy available at: https://twitter.com/privacy. Your privacy preferences with Twitter can be modified in your account settings at https://twitter.com/account/settings.
9.6. Taboola Pixel. We use the Taboola Pixel feature, which is a use of technologies belonging to Taboola Inc. that allows us to utilize user-specific advertising based on surfing behavior and customer interests. Taboola uses cookies (or similar technologies) to determine which websites you visit frequently and record your movements on our website. Tabool a gather device-related data and protocol data and creates usage profiles using pseudonyms. The usage profiles are not merged with the data about the bearer of the pseudonym and do not allow conclusions to be drawn on personal data. To do this, we communicate your IP address to Taboola. This processing is carried on the legal basis of our legitimate economic interest (Art. 6 paragraph 1 letter f GDPR.) You can object to inclusion in the tracking via the following link: https://www.taboola.com/privacy-policy#user-choices-and-optout. Once you have successfully opted out, you will no longer see personalized content/adverts.
9.7. Outbrain Pixel. We use the Outbrain pixel of Outbrain UK Limited, London, UK (www.outbrain.com) due to our justified interests in analysis and optimization of our Website and App. The purpose of the Outbrain pixel is to provide analysis related to our campaigns (ads) and advanced targeting capabilities. The Outbrain pixel only tracks activity on an anonymous basis. The Outbrain pixel does not track or collect any personal data. For more information about Outbrain pixels, see Out brain’s privacy policy available at: http://www.outbrain.com/legal/privacy. In order to contradict this data collection and storage at any time also for the future, please click here: http://www.outbrain.com/legal/privacy where you will find adetailed explanation and listing of the various opt-out options.
9.8. Intercom.io. We collect personal information such as your email address and your user activity through the use of Intercom. Intercom’s ability to use and share information is governed by the Intercom Terms of Service, available at https://docs.intercom.io/ terms, and the Intercom Privacy Policy, available at https://docs.intercom.io/privacy/.
9.9. Hotjar. We collect non personal Identifiable information such as your user activity through the use of Hotjar. Hotjar’s ability to use and share information is governed by the Hotjar Privacy Policy, available at https://www.hotjar.com/privacy/. You can opt-out of Hotjar’s services by clicking on the following link https://www.hotjar.com/policies/do-not-track/.
9.10.Google Tag Manager (“GTM”). Is a tag management system to manage JavaScript and HTML tags used for tracking and analytics on websites. Tags are small code elements that, among other things, are used to measure traffic and visitor behavior; to understand the effect of online advertising and social channels; to set up remarketing and orientation towards target groups; and to test and optimize websites. GTM makes it easier for us to integrate and manage our tags. We use GTM on our website to include the following tracking tools: Marke to Munchkin, Twitter tailored audience. If you have performed deactivation, GTM takes this deactivation into account. For more information about GTM’s privacy practices can be found at https://policies.google.com/privacy and terms of use at https://www.google.com/analytics/tag-manager/use-policy/.
9.11.Segment.com. We use Segment.com. to learn about the privacy practices of Segment.com. for more information please review https://segment.com/docs/legal/privacy/.
10.1.California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@getbrew.com. Please note that we will respond to one request per customer each year, unless otherwise required by law.
10.2.Our California Do Not Track Notice: We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
10.3.Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@getbrew.com.
