Privacy Policy

SendMan IO Technologies Ltd.

Last update December 20, 2020

The privacy of our users, customers and visitors is important to Us. This Privacy Policy includes a description of the information we collect, process and retain, how we use such information, the various technologies we may use for the purpose of such collection of information, and the decisions you may make regarding how your information is collected and used. This Privacy Policy applies to all SendMan SDK users, visitors to our website and to any other services we may provide (collectively, the "Services"). This Privacy Policy is not intended to override the terms of any contract you may have with SendMan, nor any rights you may have under other applicable data privacy laws.

In this Privacy Policy SendMan IO Technologies Ltd. is referred to as "SendMan", "We" or "Us". You are referred to as "Customer" or "You".

I. Introduction and Background

SendMan collects first party data through software development kits ("SDKs") that our customers use in their mobile applications. These SDKs permit app developers to send, manage, optimize and customize push notifications to users of the Apps. Additionally in order to describe and showcase our Services and company, we also own and operate our website at https://sendman.io ("Website"). This Privacy Policy will describe our practice in separate chapters to apply to each such operation of our company.

II. SDK Information

What Information We Collect

The following is a list of the information We collect or may have access to through the use of the SDK ("SDK Information")

  1. device information, such as device type and model, type and version of operating system language setting, timezone, device country.
  2. Push notification token (Created by Apple/Google's Firebase)
  3. User Behavior in regards to notifications, such as engagement, foreground/background status of the App, permissions, and session duration.
  4. Any custom information provided to us by You.

How We Use the SDK Information

We use the SDK Information to provide a variety of Services to our Customers. These services include:

  1. We use the SDK Information to offer and support push notification features such as content templating and user filtering. It may also include analyzing, customizing, and improving other features we may offer our Customers.
  2. We also use the SDK Information to provide information and analytics to our Customers about the use of their App features which are provided through the SDK, or to help App developers create or enhance their offerings.

How We Share SDK Information and Why

We share SDK Information with our Service Providers in order to allow Us to provide the Service to you in the most efficient and trusted manner. We rely on certain trusted third-party service providers such as AWS and MongoDB Atlas to power and operate our Services and their functionality.

We do not disclose your SDK Information to any third parties (other than our services providers) except in the limited circumstances detailed below. Our service providers do not have permission to use the SDK Information for any purpose other than to provide us the services we require to serve You.

We share certain information we collect or receive from You for the purpose of billing and payment, marketing, data enhancement and other operational or support purposes only.

For avoidance of doubt SendMan does not share SDK Information with third parties except those who process the data on Our behalf for the purposes stated above, and only if:

  1. We have Your consent (by approving this Privacy Policy)
  2. The Information is provided in order to:

    i. comply in good faith with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas;
    ii. enforce our Terms of Service or other agreements; or
    iii. protect our rights, property, or safety or the rights, property, or safety of our users or any other person or entity

  3. It is required as part of an investment transactions, M&A or such other due diligence process for, a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, any information we have may be one of the transferred assets) or in the event of bankruptcy.

SendMan As A Processor Under GDPR

For the purposes of compliance with the European Union’s General Data Protection Regulation (GDPR), with respect to all SDK Information, You, the Customer, are the Controller (as such term is used in the GDPR) of any Personal Information (As such term is defined in the GDPR) which is part of the SDK information. SendMan is the Processor (as such term is defined in the GDPR) carrying out data processing activities and instructions on your behalf as Controller.

Retention of Information

We retain all SDK information (including any Personal Information) for as long as you use our Services, and thereafter for an additional lawfully permitted period of time as necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes.

Confidentiality, security, and data integrity

We take great precautions to protect the integrity of the SDK Information. However, no data transmission over the Internet or stored on any other network or system can be guaranteed to be 100% secure. While we strive to protect information on our systems we cannot and do not guarantee the security of the SDK Information.

III. Website Information

To provide you with our Services through the Website, we collect certain Personal Information relating to an identified or identifiable natural person ("Website Information"). We collect Website Information You provide Us, from Your use of the Website and registration to the Services. The Website Information may contain and include certain types of Personal Information (as such term is defined in the GDPR). Here are the types of Personal Information we collect about you:

Information You Provide Us

When you purchase our Services through the Website and/or when you contact Us directly by any communication channel (e.g., emails or through the Website by leaving information in the required pages for support or marketing purposes), you will be requested to provide Us certain Personal Information such as name, email address, payment information, information you include in your communications with Us through any free form on our platform.

Information We Collect When You Visit the Website

When you visit our Website we may collect aggregated usage Personal Information, such as Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.

In this context we may use Cookies. For additional information about what Cookies are and the Cookies we use please see the relevant section below.

Information We Collect From Other Sources

We may receive Personal Information about you from third-party sources for various marketing purposes (such as social network platforms); in some cases, We may collect Personal Information from lead enhancement companies which help us improve our service offering; and we collect Personal Information from advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

How We use the Website Information

We use the Website Information (alone or in combination) to provide, market, and operate Our Website. Among other things, by collecting the Website Information, we are able to:

  1. Maintain and offer access to the Website and optimize how it is offered to You;
  2. Send information about Our products and services, including marketing communications;
  3. Respond to Your questions, concerns, or customer service inquiries.
  4. Customize the content and advertising You see on the Website, across the Internet, and in Social Media.

How We Share the Website Information

We may share the Website Information in the following instances and for the these purposes:

  1. As part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization or liquidation, or in connection with steps taken in anticipation of such an event (e.g., due diligence);
  2. With our corporate affiliates;
  3. With third parties that help us provide the Websites, such as entities that help us make the Websites available and functional (such as hosting services); entities that help us make available or transmit any information we hold (such as helping us send emails, process payments, and manage customer information); and entities that help us (including our contractors, agents, and affiliates) provide technical, customer, billing, administrative, marketing or operational services;
  4. When required by law or in response to lawful process, such as a subpoena, or to cooperate in good faith with a request from a government or law enforcement agency or official;
  5. If we believe sharing the information may prevent physical, financial or other harm, injury or loss; or we believe is necessary to protect our, or any other person’s or entity’s, interests; or in connection with an investigation of suspected or actual unlawful activity;
  6. We also may disclose your information under circumstances not mentioned here with your prior consent.

Cookies and Pixel Tags

Cookies are small data files containing a string of characters, such as an anonymous unique browser identifier. Cookies are stored on your computer or other device and act as unique tags that identify your device or browser. Our servers may send your device a cookie when you visit the Website, and our Customers and partners may do likewise on our Website. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access web pages on which a pixel tag is deployed, the pixel tag may generate a generic notice of the visit and permit SendMan or Our partners to set or read cookies. Pixel tags are used in combination with cookies to anonymously track the activity on a website by a particular browser on a particular device. If you disable cookies, pixel tags simply detect an anonymous Website visit.

If You reject the cookie, You may still use the Websites with the only drawback being the disablement of some of the usability features of the Websites.

Most browsers will allow You to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored.

Most web browsers accept cookies by default. If You prefer, you can disable cookies by default through each of your browser settings. Please keep in mind that settings are unique to each browser and system, so if you use multiple devices, such as computers, tablets and phones, the settings will need to be modified on each.

Below is a list of the Cookies We use:

  • On our marketing site, sendman.io:

    • tawk.to (Chat support)
    • Amplitude (User analytics)
    • Google Analytics (Aggregated Site analytics)
    • Non critical functional preferences in the Local Storage cookie
  • On our dashboard, console.sendman.io

    • Amplitude (User analytics)
    • Important functional information and some non-critical preferences are stored in the Local Storage cookie

SendMan as Controller for Web Information Under GDPR

For the purposes of compliance with the European Union’s General Data Protection Regulation (GDPR), with respect to all Web Information, SendMan is the Controller (as such term is used in the GDPR) of any Personal Information (As such term is defined in the GDPR) which is part of the Website Information.

IV. Privacy Rights

In general, with respect to all of the Personal Information which is part of the SDK Information and/or the Website Information, You may have the following privacy rights:

  1. If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us at privacy@sendman.io.
  2. In addition, if you are a resident of the European Union or the United Kingdom, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. You can exercise these rights by contacting us at privacy@sendman.io.
  3. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "opt-out" link in the marketing communications we send you or by contacting us at privacy@sendman.io.
  4. If we collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  5. You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local supervisory authority.

We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

V. Processing Personal Information (EU and UK Visitors Only)

If you are a visitor to our Website, you are Our customer or you have used an App with our SDK, from the EU or the United Kingdom, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from You only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from You or may otherwise need the Personal Information to protect your vital interests or those of another person.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us at privacy@sendman.io.

VI. Processing Personal Information (California Residents Only)

As a California resident, You have the rights listed below. However, these rights are not absolute, and in certain cases we may decline Your request as permitted by law.

You can request the following information about how we have collected and used Your Personal Information during the past 12 months:

  1. You can request a copy of the Personal Information that we have collected and retained about you during the past 12 months.
  2. You can ask us to delete the Personal Information that we have collected from you.
  3. You are entitled to exercise the rights described above without being penalized for exercising your rights by taking actions such as denying you services, increasing the price/rate of services, decreasing service quality, or suggesting that We may penalize You as described above for exercising your rights.
  4. The categories of Personal Information that We have collected.
  5. The categories of sources from which we collected Personal Information.
  6. The business or commercial purpose for collecting and/or selling Personal Information.
  7. The categories of Third Parties with whom we share Personal Information.
  8. Whether We have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
  9. Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.

You can request to exercise your information, access and deletion rights by contacting us at privacy@sendman.io. We will need to confirm your identity and California residency to process your information, access or deletion requests, and we reserve the right to confirm your California residency.

VII. Cross-border Personal Information transfers and Privacy Shield

SDK Information and Website Information is hosted in a cloud environment selected by Us and which may be either in the EU or outside the EU. Our staff located in Israel have access to all such data.

We materially comply with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, EEA, the United Kingdom, and Switzerland to the United States, in reliance on the Privacy Shield. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

In compliance with the Privacy Shield Principles, SendMan commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact SendMan at: privacy@sendman.io.

VIII. Contacting SendMan about Privacy Notice

Any inquiries, concerns, or requests regarding the use or disclosure of your Personal Information should be directed to us at: privacy@sendman.io.

IX. Changes to this Privacy Notice

This Privacy Notice was last changed on the date set forth at the top of this Privacy Notice. We may update this Privacy Notice at any time and any such changes will become effective prospectively from the date of publication. We encourage you to check this page frequently for any changes to our Privacy Notice.

Questions or comments? Email us at hello@sendman.io