Exelot Ltd. including our subsidiaries and affiliates (“Exelot”, “we”, “our” or “us”), puts great efforts in communicating our data practices and in making sure that the data we process is safe and used properly.
(i) Prospect data concerning our prospective partners, customers or website visitors, who visit or engage with our websites (such as https://www.exelot.com/ and their subdomains), social media pages, blogs, or other similar forums, online ads and content, emails or other communications under our control (collectively, the “Sites”), or participate in events or webinars that we organize or take part in (collectively, “Prospects”).
(ii) Customer data concerning global e-commerce stores (“Customers”) and their authorized users (“Users”) who have engaged with us, including account, contact and activity data relating to their use of the Exelot Platform and other tools and features provided by us as part of the services (the “Platform”, and together with the Sites, the “Services”);
(iii) Recipient data concerning the customers of our Customers (“Recipients”), who are the recipients of packages sent via Exelot’s logistic solutions for cross-border shipping and delivery.
- Data Collection
- Data Uses
- Data Location
- Data Retention
- Data Security
- Data Sharing
- Cookies and Tracking Technologies
- Data Subject Rights
- Roles & Responsibilities
- Additional Information and Contact Details
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined in Section 6 below), please avoid any interaction with us or any use of our Services (or certain parts of our Services). If you are a User of the Platform on behalf of any of our Customers, we suggest that you contact your account administrator with any questions.
1. Data Collection
The data we process regarding our Prospects, Customers and their Users and Recipients (“you” or “your”), is typically collected and generated through automatic means, directly from you, through your interaction with us or with our Services; from our Customers, who provide us with their Users’ and Recipients’ data; or through third-party services, social media, analytics tools, events we organize or take part in, and other business initiatives.
(i) Prospect data:
- Prospect contact information: contact and business details and interests, which may also contain the details of an internal contact person who may be relevant for facilitating and managing the relationship between the parties, e.g., potential business and technical owners, account administrators, billing contacts and authorized signatories;
- Direct interactions and communications with us: correspondence with us, as well as chats, surveys, feedbacks, transcripts, your interactions with the website, and analyses thereof, as well as any needs, preferences, attributes and insights relevant to our potential engagement;
- Sites usage information: connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (such as type, OS, device id, browser version, locale and language settings used), geolocation (if applicable), connectivity data, activity, communication and performance logs, session recordings, issues and bugs, and the cookies and pixels installed or utilized on the Prospect’s device.
(ii) User Data:
- User account information: e-mail address and, when applicable, username, hashed password or other information used for authentication and access control;
- Profile and contact information: full name, workplace and position, contact details (such as business e-mail, phone number and address), as well as and any additional information and media submitted by the Users or their organization;
- Direct interactions and communications: correspondence, chats, surveys, feedbacks, your interactions with the Platform and other users within the Platform, transcriptions and analyses thereof, as well as any needs, preferences, attributes and insights relevant to our potential engagement, e.g., for user enablement, support and training purposes;
- Payment information: billing details, billing contacts and authorized signatories on behalf of the Customer, business needs and payment preferences. To the extent that any of the foregoing solely relates to a non-human entity, we will not regard it as personal data, and this Policy will not apply to it;
- Platform usage information: connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (such as type, OS, device id, browser version, locale and language settings used), geolocation (if applicable), connectivity data, activity, communication and performance logs, session recordings, issues and bugs, and the cookies installed or utilized on the User’s device.
(iii) Recipient Data:
- Contact information: full name, e-mail address, phone number, home address and zip code;
- Shipping and related Services information: shipment status, tracking number and routing information, delivery address, return information, package type, weight, number of items and customs information. To the extent that any of the foregoing solely relates to a non-human entity, we will not regard it as personal data, and this Policy will not apply to it;
- Communication and preferences information (if applicable): direct interactions with us, such as correspondence, chats, surveys, feedbacks, including transcriptions and analyses thereof, as well as any needs, preferences, attributes and insights relevant to our potential engagement, e.g., for user enablement, support and training purposes; including history of purchases and delivery addresses, as well as any related commercial activities;
- Identification and payment information (if applicable): In some cases, we may collect the Recipient’s government-issued identification number and the relevant payment method, e.g., when releasing a package from customs on behalf of the Recipient, or when a special delivery is requested;
- Sites and Platform Usage information: connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (such as type, OS, device id, browser version, locale and language settings used), geolocation (if applicable), connectivity data, activity, communication and performance logs, session recordings, issues and bugs, and the cookies installed or utilized on the User’s device.
2. Data Uses
Exelot processes the personal data described in Section 1 as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining, improving and advertising our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Services, ourselves and the organizations and individuals we engage with.
Specifically, we use your data for the following purposes:
- To facilitate, operate, and provide our Services;
- To authenticate your identity and allow you to access and use our Services;
- To provide our Users and Customers with customer care, assistance and technical support services;
- To train and improve our algorithms, and to further develop, customize and improve the Services, and to improve user experience, based on common or personal preferences, experiences and difficulties;
- To facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively;
- To contact you with general or personalized service-related messages (such as password-retrieval or billing), or with promotional messages (such as newsletters, special offers, new features etc.) in accordance with Section 8 below, and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal), which we or our business partners and Customers may use to provide and improve our respective services, or for any other purpose; and
- To comply with applicable laws and regulations.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
3. Data Location
We and our authorized Service Providers maintain, store and process personal data in the various locations we operate around the globe, including in Israel, the EU, the UK, and the US, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
4. Data Retention
We retain your personal data for as long as it is reasonably necessary to provide you with our Services and offerings and to maintain and expand our relationship; to comply with our legal and contractual obligations (for example, if required to prove customs clearance); or to protect ourselves from any potential disputes (e.g. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with applicable laws and regulations, and where applicable, also with our Customer’s reasonable instructions and as further stipulated in our DPA and other commercial agreements with such Customer.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at firstname.lastname@example.org.
Please also note that we do not retain your payment information, it will be provided directly to the relevant Service Provider (as per Section 6 below). We only retain a transaction number, which cannot be used to reidentify your credit card or any payment information.
5. Data Security
We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information, including using 128-bit SSL encryption (secure socket layer) when needed. These measures provide sound industry-standard security, however, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
6. Data Sharing
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. 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.
Service Providers: we engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), data analytics services (including Google Analytics, as further explained in Section 7 below), marketing and advertising services, data and cyber-security services, fraud detection and prevention services, storage and logistics services, delivery and carriers companies, customs agents and customs authorities, customer relationship and engagement services, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating, supporting and enhancing our Services, and may only use it for such purposes.
Sharing Data with our Customers and their Users: Recipients’ data is typically available to Users within the Customer’s account. Users’ data is shared with the administrator of the same Customer’s account to which such User belongs (including data and communications concerning such User’s account). In such cases, sharing such data means that the administrator or other Users of the account may access it on behalf of the Customer, and will be able to monitor, process and analyze the personal data contained therein. This includes instances where you may contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same Customer). Please note that Exelot is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the ‘data controller’ of such data (as further described in Section 10 below).
Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Exelot, any of our Visitors, Users or Customers, or any members of the general public.
Exelot Subsidiaries and Affiliated Companies; Change of Control: we may share personal data internally within our group, for the purposes described in this Policy. In addition, should Exelot Ltd .or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, personal data may be shared with the parties involved in such an event. If we believe that such event might materially affect any 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.
Additional Sharing: Exelot may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
7. Cookies and Tracking Technologies
We and our Service Providers use “cookies” and other technologies for performance, tracking, analytics and personalization purposes and in order to provide you with a better experience. We may share non-identifiable/aggregated extracts of such information with our partners for our legitimate business purposes.
Cookies: cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session - these are the “session cookies”. Some last for longer periods and are called “persistent cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools. Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
We engage in service and promotional communications, through e-mail, phone, SMS and notifications with our Users.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset instructions, etc. Our Customers may also use our Services to send their Users on the same Customer account notifications, messages and other updates regarding their or your use of the Services. You can control your communications and notifications settings in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use of the Services (like password resets or billing notices).
Notifications and Promotional Communications: we and our authorized partners (e.g., event or webinar co-sponsors) may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., SMS, phone, mobile or e-mail), through the Platform or Sites, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Exelot at any time by sending an e-mail to: email@example.com or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
9. Data Subject Rights
Individuals have rights concerning their personal data. If you wish to exercise your privacy rights under any applicable law, including the EU and UK General Data Protection Regulation (GDPR), or the CCPA, such as the right to request access to, and rectification or erasure of your personal data held with Exelot, or to restrict or object to such personal data’s processing, or to port such personal data, or the right to equal services and prices, (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: firstname.lastname@example.org.
Please note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Please also note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
If you would like to make any requests or queries regarding data we process on our Customer’s behalf, please contact the administrator of such Customer’s account directly. For example, if you are a User or a Recipient of our Customer and you wish to access, correct, or delete data processed by Exelot on behalf of our Customer, please direct your request to the relevant Customer (who is the “data controller” of such data – see Section 10 below). Note that if you do contact us, we may share your communications with our Customer and its Users.
10. Roles & Responsibilities
Certain data protection laws and regulations, such as the GDPR or the CCPA typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), 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.
(ii) With respect to Recipient data, Exelot assumes the responsibilities of a “data processor”, processing the data on behalf of our Customer. In such instances, our Service Providers processing such data will assume the role of “sub-processors”.
Accordingly, Exelot processes Recipients personal data strictly in accordance with such Customer’s reasonable instructions and as further stipulated in our DPA and other commercial agreements with such Customer. The Customer, as controller of such data, will be responsible for meeting any legal requirements applicable to business. For the avoidance of doubt, each Customer is solely responsible for providing adequate notice to their Users and Recipients whose personal data may be processed – including sufficient reference to the processing of their personal data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
11. Additional Information and Contact Details
Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best 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 e-mail at email@example.com.
EU & UK Representatives: Exel-Med Limited (our subsidiary located in Cyprus) and Exelot UK Ltd. (our UK subsidiary) have been designated as Exelot’s representatives in the European Union and the United Kingdom, respectively, for data protection matters. They may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to firstname.lastname@example.org while stating the relevant entity you would like to contact. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority or the UK Information Commissioner's Office (ICO).
Effective Date: December 24, 2021