Last Updated: September 2022

This privacy policy (“Privacy Policy”) governs how we, Coho AI Ltd. (together, ״Coho AI“, “Coho” “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:

1. When you browse or visit our website, [https://www.coho.ai/]  (“Website”);
2. When you make use of, or interact with, our Website
   1. When you submit information via our Website forms (e.g., “contact us” form)
   2. When you request a free trial or book a demo
   3. When we process your job application
3. When you make use of, or interact with, Coho platform (the “Platform”)
   1. When you create an account, log-in and make use of the Platform 
4. When you attend a marketing event and/or we exchange business cards or otherwise provide us with your Personal Data for marketing purposes
5. When we use the Personal Data of our customers, prospects, vendors or service providers (e.g. contact details) 
6. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn) 

Please read this Privacy Policy carefully, so you can understand our practices and your rights 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 and any information deemed as Personally Identifiable Information by privacy laws. 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 to 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. 

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.

What information we collect, why we collect it and how it is used

• Specific Personal Data we collect	Why is the Personal Data collected and for what purposes?		Legal basis (GDPR only, if applicable)
  When you browse or visit our Website
  Cookies, analytic tools and log files For more information, please read our cookies policy [https://www.coho.ai/cookie-policy/]	Marketing, analytics, statistics, improvements.		Consent Legitimate interest (e.g. essential cookies)
  When you make use of, or interact with, our Website
  When you submit information via our Website forms and surveys (e.g., contact us form)
  Full name Company Name Email address Job Position Comments/Messages Any other data you provide	To communicate with you. To respond to your questions, comments, and other requests for ongoing customer assistance, technical support and maintenance of the Website. To perform the applicable agreement. To send you marketing communications		Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. respond to a query sent by you) Consent (for marketing)
  When you book a demo
  Full name Company Name Email address	To receive and respond to your request. To communicate with you. To send you marketing communications.		Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. respond to a query sent by you) Consent (for marketing)
  When we process your job application
  Full name Email address Phone number CV/Resume   Optional: LinkedIn profile, Personal website and other information you decide to provide us. Please note: in some cases we also receive this personal data from third parties such as recruitment agencies.	To assess you as a candidate. To analyze your application.  To communicate with you.		Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract  Legitimate interest (e.g. to assess you as a candidate)
  When you create an account, log-in and make use of the Platform
  Full name Email address User ID and Password IP address Job position/title		To create your account and allow you to create the admin and regular users To allow you to log in/sign up to the Platform To fulfill your requests for our services and related activities (e.g., account management, support) To perform/execute the relevant agreement To grant you access to the services (our Platform)	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to allow you to sign up to the Platform)
  IP address Usage pattern of the Platform		To monitor your use of the Platform To assist you with support services To improve the services	Legitimate interest (e.g., to customize your experience)
  When you attend a marketing event, we exchange business cards or otherwise provide us with your Personal Data for marketing purposes
  Full name  Email address  Company name Job title Phone Number Any other data you provide	To establish a business connection.  To send you marketing communications.		Consent and, depending on the situation, legitimate interest (e.g. showing you certain services that you have shown an interest in in a B2B situation).
  When we use the personal data of our customers, prospects, vendors or service providers  (e.g. contact details)
  Full name  Email address Physical address Phone number  Company name and details Payment information Any other information that you decide to provide  us with	To provide our products and services. To perform the applicable agreement. To communicate with you.		Processing is necessary for the performance of a contract to which our customer is a party Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.) Legitimate interest (e.g. send you contract-related communications) Cannot provide our products and services
  When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
  Full name Email address Social media channel Any other data you decide to provide us with	To respond to your requests via our social media channels To send you marketing communications.		Legitimate interest (e.g. respond to your requests in our social media channels) Consent (marketing)

Finally, please note that some of the above mentioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. 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 or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “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). 

How we protect and retain your information

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.

1. Retention of your Personal Data. Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that 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 cookie policy – https://www.coho.ai/cookie-policy/]. 

How we share your personal data

We may share your Personal Data as follows:

1. With our service providers, such as:

1. Our cloud service providers for hosting purposes;
2. Our websites and web content creation platforms in order to help us manage our Website;
3. Our email providers, marketing, CRM and other similar tool providers; and
4. Our analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.

1. With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies. 
2. 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. 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;
4. 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, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or 
5. 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).

Additional information regarding transfers of personal data

1. Storage: We store the Personal Data with the following storing companies: AWS – Ireland, Snowflake – Ireland.

1. External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When Coho AI engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. Coho AI also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR. 

Your privacy rights. How to delete your account. 

• 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):

• 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;
• You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
• 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;
• You have the right to object, to or to request restriction, of the processing;
• 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;
• You have the right to object to profiling;
• 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;
• 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;
• 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@coho.ai.  You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. 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 fulfill 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. 

Deleting your account

Should you ever decide to delete your account, you may do so by emailing privacy@coho.ai. 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. 

Use by children

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@coho.ai. 

Interaction with third-party products

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.

Log files

We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

Analytic tools

• 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 we collect. 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 https://marketingplatform.google.com/about/analytics/terms/us/, 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/. 

We reserve the right to remove or add new analytic tools.

Specific revisions applicable under California Privacy law

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 privacy@coho.ai. Please note that we are only required to respond to one request per customer each year.

1. 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 22581 permits 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.

Contact us

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 privacy@coho.ai.