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Privacy Policy & Terms

TERMS OF SERVICE

Welcome to www.sosa.co (“Website“).

The Website is owned and operated by SOSA HOLDINGS LTD., Reg. No. 514620103 and its affiliates (“SOSA“, “we“, “our“, or “us“). 

Read carefully the following terms of service (“Terms“), together with our privacy policy and cookie policy, both serve as integral parts of the Terms, because they constitute a binding agreement between you, the individual or entity accessing or using the Website, and SOSA.

By accessing the Website or by using it in any other manner, you signify your acceptance of the Terms. If you do not agree to the Terms, you may not access or use the Website.

Our Website and Services are not directed to individuals under the age of 18. If you are under the age of 18, you do not have authorization or permission to use the Website or access our Services.

If you have questions or comments about the Terms, feel free to contact us at: Info@sosa.co.

Our Services

SOSA holds and maintains a global innovation platform connecting corporations, governments and cities to innovative technologies and ecosystems (collectively, “Services“).

Note that SOSA’s services for business partners and tenants are subject to separate agreements. Therefore, the Terms cover the acceptable use of the Website in order to contact us about potential business relations, including to provide you with the Services.

In addition, and subject to Terms, we may offer you free content on the Website, including, without limitation, SOSA’s community, blog, and newsletter

All information and materials presented on the Website are SOSA’s sole property. For the sake of clarity, we reserve all rights not expressly granted in the Terms.

Note that the Terms cover the terms and conditions to use the Website and Services. SOSA’s services for business partners and tenants are subject to separate agreements.

Termination

We can suspend or terminate your rights to use the Website or Services, at any time, at our sole discretion and without prior notice, if we believe that you have breached the Terms. Any termination of your subscription may involve the deletion of your information from our systems.

Grant of Right

Subject to the Terms, we grant you a worldwide, limited, non-exclusive, revocable, non-transferable right to use the Website. For the sake of clarity, you may use the Website’s tools and features that we make available for their intended purpose only. 

Links

The Website contains links to other websites, information, and content provided by third parties. We do not operate or monitor these websites and content. You may find these websites, or the information and content posted therein, not compatible with your requirements, objectionable, annoying, improper, unlawful or immoral. 

By linking to a certain website, we do not endorse, or sponsor its content, or confirm its accuracy, credibility, authenticity, reliability, validity, integrity, or legality. We assume no responsibility for such third-party websites or content, or their availability or any transactions made between you and such third-party websites.

Accordingly, we will not be liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with your use of or reliance on any such content, goods or services available on or through any third-party websites or content.

Website’s Changes and Availability

We may from time to time change the Website’s structure, layout, design or display, as well as the scope and availability of the information and content therein, without giving any prior notice.

Changes of this character by their very nature are likely to result in glitches or cause inconvenience. We will not be held responsible for any outcome of these changes, and failures resulting from them.

Website’s Operation

We will make commercially reasonable efforts to run the Website efficiently and accessible at all times, subject to our right to discontinue, temporarily or permanently, the operation of the Website, or any part thereof, or block, remove or delete any content from the Website at our sole discretion and without prior notice.

However, the Website’s operation is dependent upon various factors such as software, hardware, and communication networks. By their nature, these factors are not fault-free.

Accordingly, we do not warrant that the Website will operate in an uninterrupted or error-free manner, or that it will always be available, free from all harmful components, or that at all times it will be completely safe, and secured from unauthorized access to our computers, immune from damages, free of malfunctions, bugs or failures, including, but not limited to, hardware failures, software failures, and software communication failures, originating either in us or any other service provider.

For the sake of clarity, such incidents and activities will not be considered a breach of the Terms.

Unacceptable Use

You may not access or use the Website or Services –

  • for or in connection with any activity that constitutes or encourages conduct that would – 
  1. constitute a criminal offense;
  2. give rise to civil liability;
  3. violate any applicable local, state, national, foreign law or industry standard, including, without limitation, any applicable laws and regulations governing intellectual property, privacy, defamation, fraud, mass email, spam, harassment, obscenity, hate-speech, export control, consumer protection, unfair competition and false advertising or any other deceptive practices; or,
  4. provide us with content that: (a) are pornographic, sexually explicit or violent; (b) reasonably likely to cause harm or could be reasonably considered as slanderous or libelous; (c) are defamatory of any person, obscene, promotes discrimination based on race, sex, religion, nationality, disability, sexual orientation or age; (d) infringe any copyright, design right, database right or trademark of any other person; (e) are likely to deceive any person, breach any legal duty owed to a third party, or promote any illegal activity.
  • to upload, post, email, transmit, record, provide a recording or otherwise make available any information and materials that infringe a third party’s right, especially privacy, publicity, and intellectual property rights; software viruses, trojan horses, worms and any other malicious application to computers and networks; and,
  • to develop or create a similar or competitive website or service to the Website or Services.

In addition, you may not use the Website for any commercial or business purpose that is not expressly permitted by the Terms, including, but not limited to, providing the Website or Services to third parties by reselling, licensing, renting, leasing, transferring, lending, timesharing, assigning, mirroring, redistributing or displaying the Website, Services or any part thereof, without our prior written and explicit permission. Without limiting the aforesaid, you may not –

  • modify any material or content that we make available on the Website, except as expressly permitted under the Terms;
  • engage in or attempt to engage in any form of testing, scanning, crawling, scraping, probing, robotic navigating, bulk extracting or hacking the Website;
  • interfere with, burden or disrupt the functionality of the Website;
  • circumvent, impair or manipulate the operation of the Website;
  • work around or circumvent any technical limitations in the Website or use any tool to enable features or functionalities that are otherwise disabled, inaccessible or undocumented in the Website;
  • embed, frame or otherwise link directly to the Website, from any other webpage, application or other resources, without our prior written permission;
  • engage in any false, misleading or deceptive acts or practices involving the Website or your identity, agency or affiliation with any person or entity; and, 
  • breach the security of the Website, or any network or server used by the Website. 

To the maximum extent permitted by law, we may at any time, at our sole discretion and without prior notice, delete or modify any material from our Website and servers, in whole or in part.

Your Rights

We respect your rights. For example, we recognize that in some countries, you may have legal rights as a consumer. If you are using the Website or Services for a personal purpose, then nothing in the Terms limits any consumer legal rights which may not be waived by contract.

Accordingly, if you believe that your rights are abused on our Website or Services, you may contact us at: Info@sosa.co. We may ask you to provide us with additional information to process your complaint. We will make commercially reasonable efforts to review your complaint and respond promptly. Note that we will not respond to anonymous complaints.

Your Subscription

Subject to our Privacy Policy, if you provide us with information, you must fully and accurately provide such information, as requested by us, and promptly update such information, where needed.

You need to cooperate with us, including by providing us with relevant information we may request to provide you with the Services.

For the sake of clarity, you are solely responsible for the accuracy, appropriateness and lawfulness of all information and content you provide us. 

Correction of Errors

We make commercially reasonable efforts to ensure the reliability and availability of the Website. However, errors, mistakes, and malfunctions may occur from time to time. Please help us to maintain a high level of service by contacting us at: Info@sosa.co about any potential errors, mistakes, and malfunctions.

Intellectual Property

Unless expressly stated otherwise by us in writing, all information and materials available on the Website are SOSA’s sole property or licensed to SOSA by third parties.

We do not grant you any rights to patents, copyrights, trademarks (whether registered or unregistered), trade names, trade secrets, domain names or any other rights, functions or licenses concerning the Website, and we reserve all rights not expressly granted in the Terms.

For the sake of clarity, and without limiting the above said, the Website’s trademarks (whether registered or not), domain names, and copyrights, as well as SOSA’s name and logo, are SOSA’s sole property. You may not use them, or any confusingly similar mark or text, without our prior express written consent.

Note, however, that we do not claim ownership over your content. Accordingly, when you upload any type of content to the Website, you represent and warrant that you do not violate any third party’s rights.

We will use content that you share with us through the Website for the following purposes: (i) addressing your request; (ii) improving our Website and Services; or, (iii) legal defense, where applicable. 

DISCLAIMER OF WARRANTY

YOU ACKNOWLEDGE AND AGREE THAT THE WEBSITE AND SERVICES ARE PROVIDED FOR USE “AS IS”, WITHOUT ANY WARRANTIES OF ACCURACY, RELIABILITY, LIKELY-RESULT, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, COMPATIBILITY, SECURITY OR BEING UP TO DATE.

ANY USE OF THE WEBSITE AND SERVICES ARE AT YOUR SOLE RISK.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE EXPRESSLY DISCLAIM ANY WARRANTIES, CONDITIONS, REPRESENTATIONS, AND GUARANTEES CONCERNING THE WEBSITE AND SERVICES, THE ACCURACY, RELIABILITY, ADEQUACY OR COMPLETENESS OF THE WEBSITE AND SERVICES OR ANY OTHER MATERIAL PROVIDED BY ANY LINK TO ANOTHER WEBSITE OR SERVICE, WHETHER EXPRESS OR IMPLIED, ARISING BY LAW, CUSTOM, PRIOR ORAL OR WRITTEN STATEMENTS, OR OTHERWISE, INCLUDING, WITHOUT LIMITATION, ANY WARRANTY OF MERCHANTABILITY, LIKELY-RESULT, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT.

NO REPRESENTATION OR OTHER AFFIRMATION OF FACT, INCLUDING, WITHOUT LIMITATION, STATEMENTS REGARDING CAPACITY, SUITABILITY FOR USE OR PERFORMANCE OF THE WEBSITE AND SERVICES, WHETHER MADE BY OUR EMPLOYEES OR OTHERWISE, WHICH IS NOT CONTAINED IN THE TERMS, WILL BE DEEMED TO BE A WARRANTY BY US FOR ANY PURPOSE, OR GIVE RISE TO ANY LIABILITY OF US WHATSOEVER.

LIMITATION OF LIABILITY

WE, AND OUR EMPLOYEES, DIRECTORS, SHAREHOLDERS, ADVISORS, OR ANYONE ACTING ON OUR BEHALF, WILL NOT BE LIABLE TO YOU OR ANY OTHER PERSON CONCERNING THE WEBSITE’S OR SERVICES’ PROPERTIES, ABILITIES, LIMITATIONS, FITNESS TO YOUR NEEDS, OR CONCERNING ANY CONTENT AVAILABLE ON OR UNAVAILABLE THROUGH THE WEBSITE OR SERVICES.

WE, AND OUR EMPLOYEES, DIRECTORS, SHAREHOLDERS, ADVISORS OR ANYONE ACTING ON OUR BEHALF, WILL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGE, OR ANY OTHER DAMAGE, AND LOSS (INCLUDING LOSS OF PROFIT AND LOSS OF DATA), COSTS, EXPENSES, AND PAYMENTS, EITHER IN TORT, CONTRACTUAL, OR IN ANY OTHER FORM OF LIABILITY, ARISING FROM, OR IN CONNECTION WITH THE USE OF, OR THE INABILITY TO USE THE WEBSITE, OR ANY FAILURE, ERROR, OR BREAKDOWN IN THE FUNCTION OF THE WEBSITE, OR FROM ANY FAULT OR ERROR MADE BY OUR STAFF OR ANYONE ACTING ON OUR BEHALF, OR FROM YOUR RELIANCE ON THE CONTENT OR MATERIAL ORIGINATING FROM THIRD PARTIES, OR ANY COMMUNICATION WITH US OR WITH OTHER USERS IN CONNECTION WITH THE WEBSITE – WHETHER OR NOT WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE, LOSS, COSTS, EXPENSES OR PAYMENTS.

INDEMNIFICATION

YOU WILL INDEMNIFY, DEFEND AND HOLD HARMLESS US, OUR EMPLOYEES, DIRECTORS, SHAREHOLDERS, ADVISORS OR ANYONE ACTING ON OUR BEHALF FROM AND AGAINST ANY CLAIMS, DEMANDS, DAMAGES, LOSSES (INCLUDING, WITHOUT LIMITATION, LOSS OF PROFIT), PAYMENTS OR EXPENSES, INCLUDING LEGAL EXPENSES AND ATTORNEY FEES, THAT WE INCUR IN CONNECTION WITH YOUR BREACH OF THE TERMS OR ANY UNLAWFUL OR TORTUOUS ACTION OR INACTION BY YOU OR ANYONE ON YOUR BEHALF CONCERNING THE WEBSITE AND SERVICES.

Changes and Additions

We may change the Terms to meet technical, operational and legal requirements. We will post a notice about changes made to the Terms on the Website or via email (the “Notice“).

Unless required otherwise to comply with applicable laws, rules, regulations, and agreements, all minor changes (which have minor, if any, consequences) will take effect 7 days after we post or send the Notice, and substantial changes will be effective 30 days after post or send the Notice.

We may modify, enhance, or improve the Website and Services, and may accordingly offer additional tools and features. Such additional tools and features may be governed by additional or different terms, as provided by us, where applicable.

Governing Law and Jurisdiction

If the value of the relief sought is 10,000 US dollars or less, the parties will make good faith efforts to resolve the dispute between them amicably. If such direct talks fail to resolve the dispute, each party may initiate an alternative dispute resolution (“ADR“) process with an established ADR service provider. 

You and us will agree on the identity of the ADR service provider and the dispute will be conducted in English, only by written submissions through e-mail correspondence or other electronic communications, or through telephone or video conversations and without the need for personal appearance. Any judgment on the award rendered by the ADR provider may be entered in any court of competent jurisdiction.

If the value of the relief sought is more than 10,000 US dollars, the Terms and any claim, cause of action or dispute arising out of or related thereto, will be governed solely by the laws of the State of Israel, regardless of your country of origin or where you access the Website, and without giving effect to any conflicts of law principles, which would result in the application of the laws of a jurisdiction other than the State of Israel. 

The competent courts in Tel Aviv, Israel will have sole and exclusive jurisdiction concerning the Terms and any claim, cause of action or dispute arising out of or related thereto. You hereby agree to the exclusive jurisdiction of the above-mentioned courts, agree to accept service of process by any means permitted by the applicable law and waive any jurisdictional, conflict of law or venue defenses otherwise available to you.

Entire Agreement

The Terms, which also include our privacy policy and cookie policy, constitute the entire agreement between you and SOSA.

The Terms supersede any agreements, negotiations, and understandings, whether written or oral, and no waiver, concession, extension, representation, alteration, addition or derogation from the Terms will be effective unless expressly stated otherwise by us in writing.

Assignment 

We may assign or transfer our rights or obligations under the Terms to any third party, provided, however, that your rights under the Terms are not compromised by such assignment or transfer.

You may NOT assign or transfer your rights or obligations under the Terms without our prior written consent. Any attempted or actual assignment or transfer by you will be null and void, unless expressly stated otherwise by us in writing.

Interpretation

The paragraph headings herein are intended solely for the purpose of orientation and reading convenience and will not be used for interpretation purposes.

Severability

If any provision of the Terms is held by a court of competent jurisdiction to be illegal, invalid, unenforceable, or otherwise contrary to law, the remaining provisions of the Terms will remain in full force and effect, to the maximum extent.

Last Updated: January 7, 2020.

Effective Date: February 7, 2020.

 

SOSA Privacy Policy

This privacy policy describes how we use personal information related to you, along with your options, choices, and privacy rights.

Note that you are not legally obligated to provide us with any personal information. However, if you consent to this privacy policy, the use of personal information related to you will be in accordance with the provisions herein.

Our privacy policy applies to sosa.co (the “Website”) and forms an integral part of the SOSA Terms of Service.

SOSA HOLDINGS LTD., Reg. No. 514620103 and its subsidiaries (collectively, “we”, “us”, “our”, or “SOSA”) own and operate the Website.

This privacy policy was last updated on February 1, 2020, with an effective date as of March 1, 2020, unless required otherwise under applicable law.

If you have questions or comments about our privacy policy, you are welcome to contact us at: Info@sosa.co.

What Services Do We Provide?

SOSA develops and manages a global platform that connects corporations, governments and cities to innovative technologies and ecosystems. In addition, SOSA leases office space to startups (all SOSA’s services collectively will be referred to as the “Services“).

What Types of Personal Information Do We Collect and Why?

We collect information about your company, which includes personal information about individuals. In addition, we collect (a) email addresses and billing information to provide you with the Services; (b) personal information to improve our Website, Services, and marketing activities; and, (c) personal information that you have provided us with, for example, when you contact our customer service. We use third-party service providers to hold, maintain, provide, and improve our Services.

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  • We commit to process personal information related to you solely for the purposes described below.
  • To the extent relevant and possible, we will make efforts to maintain personal information related to you accurate, complete and up to date.
  • You can register to our mailing list to receive updates and marketing materials and invitations electronically to our events (for example, see join us, become a partner or contact us).

We share your name and email address with third-party providers to send you email messages.

You can opt-out from the list by simply click on the unsubscribed request written in the received email message.

  • You hereby provide us with your freely given, specific, informed and unambiguous consent to use your name and email address for our internal and marketing purposes.

This includes, without limitation, sharing of contact details given to us with our clients, in order to contact you for business related opportunities.

  • If you use our Services to send emails to others, you acknowledge and agree to obtain their sufficient consent and send these email messages at your sole responsibility and risk.
  • If you contact our customer service, we will use the content of your message for the following purposes: (i) addressing your request; (ii) improving the Website and Services; and, (iii) legal defense, where applicable.
  • We will also process personal information related to you to improve the Website, establish statistical data about our web traffic, identify potential cases of abuse of our systems, as well as prevent cyber-attacks, fraud, and identity theft.
  • To the extent that we utilize third-party processors or providers to process personal information, we engage with them under a data processing agreement to ensure we have their contractual commitments to protect personal information and process such personal information for specific purposes. Our main marketing activities online include –
  • Google Display Network’s marketing services and features that SOSA uses, which are also subject to Google’s relevant policies and agreements and the option to opt-out from them via the Google Analytics Opt-out Browser Add-on web page, available here: google.com/dlpage/gaoptout.
  • Facebook’s marketing services and features that SOSA uses, which are also subject to Facebook’s relevant policies and agreements and the option to opt-out from them via the Facebook relevant help center page, available here: facebook.com/help/568137493302217.
  • Twitter’s marketing services and features that SOSA uses, which are also subject to Twitter Ads policies and agreements and the option to opt-out from them via the Twitter help center page, available here: twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.
  • Instagram’s marketing services and features that SOSA uses, which are also subject to Instagram Business policies and agreements and the option to opt-out from them via the Instagram Business help center page, available here: instagram.com/196883487377501, as well as the “What can I do if I see an ad I don’t like on Instagram?” page, available here: help.instagram.com/615366948510230.
  • We report and share personal information if we believe that we are required to do so by law. Furthermore, we need to disclose personal information in response to lawful requests by public authorities, including without limitation to meet national security or law enforcement requirements.
  • There are business activities, such as merger, acquisition, or investment, that require us to share personal information related to you to another entity, provided, however, that the receiving entity will comply with the relevant provisions stated in this privacy policy.
  • Your interaction with social media features, widgets, or websites are governed by the privacy policies of the applicable social media websites.
  • If you contact us via these social media websites, we will use the content of your message for the following purposes: (i) addressing your request; (ii) improving our Website and Services; and, (iii) legal defense, where applicable.

We are not responsible for any use, misuse or unlawful use of the identifiable information that you choose to post or share on these platforms.

  • We gather some information automatically, such as IP addresses, browser type, internet service providers, referral links, geo-locations and clickstream information.

If these types of information include personal information, it will be used in accordance with this privacy policy and for the following purposes: (i) provide you with the Services; (ii) improving our Website and Services; and, (iii) legal defense, where applicable.

Note that we use Google Analytics. Google Analytics uses personal information collected through the Website for purposes other than for providing us services. Please read carefully Google Analytics’ privacy policy, available here: policies.google.com/privacy?hl=en-US. You can opt-out from Google Analytics by visiting here: tools.google.com/dlpage/gaoptout.

  • We process aggregated data that is not personally identifiable information. For example, we use statistical analysis to improve our Services and share marketing data with our partners where such data do not identify individuals.

What Cookies Do We Use?

We store cookies on your device to enhance site navigation, analyze site usage, and assist in SOSA’s marketing efforts. You can manage your cookie preferences. Read More at our Cookie Policy.

What Choices Do I Have?

You can opt-out of our mailing list and terminate your use of the Website. Our Services do not respond to Do Not Track (DNT) signals.

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  • You can unsubscribe from our mailing list directly from the email sent, by choosing to opt-out in the settings portion of your account profile or sending an opt-out request to us at Info@sosa.co.
  • You can object to the transfer of personal information related to you to a third party, other than third parties who are strictly necessary for us to comply with applicable law and/or agreement.
  • You can exercise your choice by contacting us at info@sosa.co. To the extent necessary, we will ask you to provide us with necessary details to authenticate your identity and to identify information related to you on our systems.
  • Some web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference for tracking your activities on our Services or through cross-site user tracking. Our Website and Services do not respond to DNT signals.

What Personal Information Can I Access?

You can request access to personal information that we keep about you. You can also request us to correct wrong details about you or delete them from our systems.

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  • You can contact us at Info@sosa.co and request access to the personal information that we keep about you. You can also request to correct wrong details collected about you or delete them. We will consider your request in accordance with applicable laws and regulations.
  • To the extent necessary, we will ask you to provide us with certain credentials or details to make sure that you are who you claim to be.
  • Note that we can delete personal information related to you in different manners, including by removing any identifying information and transforming personal information that relates to you into anonymized data.

For How Long Do We Keep Your Personal Information?

We retain data as needed, to provide our Services and for legitimate and lawful purposes. We implement information security measures to secure personal information related to you as well as minimize the risks.

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  • We retain data as needed to provide our Services as well as for legitimate and lawful purposes. We also retain data pursuant to legal requirements under applicable laws.
  • We will make efforts to guarantee that personal information is kept for no longer than is necessary for the purposes for which the personal information is processed.
  • If we retain personal information related to you for any legitimate business purpose other than to provide our Services, we will make efforts to limit the access to the personal information and the retention time to minimum.
  • Note that we can keep aggregated non-identifiable data without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the data.

How Do We Keep Your Personal Information Secured?

  • We implement information security measures, including internal policies and procedures, to secure personal information related to you as well as minimize the risks of theft, damage, loss of data, or unauthorized access.
  • These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that our Services will be immune from any wrongdoings, malfunctions, unlawful access or other kinds of abuse and misuse.

Where Do We Store and Process Your Personal Information?

We store and process personal information in the United States, the United Kingdom, Germany, and Israel.

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  • We store and process personal information in the United States, the United Kingdom, Germany, and Israel, including sites operated and maintained by cloud-based hosting service providers in the U.S.
  • When we transfer personal information related to you out of the European Union, our transfer of personal information related to you to our cloud-based hosting service providers in the U.S. is governed by these service providers’ adherence to the Privacy Shield Framework. Please read more about the protection of personal information under this framework at privacyshield.gov.
  • If you are a resident in a jurisdiction where transfer of personal information related to you to another jurisdiction requires your consent, then you hereby provide us with your freely given, specific, informed and unambiguous consent to such transfer.

How Do We Notify You of Changes to this Privacy Policy?

We can update our privacy policy from time to time after giving a proper notice.

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  • From time to time, we can update this privacy policy. We will post a notice about changes made to this privacy policy on the Website or via email (the “Notice“).
  • Unless required otherwise to comply with applicable laws, rules, regulations, and agreements, all minor changes (which have minor, if any, consequences) will take effect 7 days after we post or send the Notice, and substantial changes will be effective 30 days after we post or send the Notice.
  • Until the new privacy policy takes effect, you can choose not to accept it and terminate your use of the Website and Services. Continuing to use the Website or Services after the new privacy policy takes effect means that you agree to the new privacy policy.
  • Note that we can modify, enhance or improve the Website and Services, and can accordingly offer additional tools and features. Where necessary, at our sole discretion, such additional tools and features will be governed by additional or different terms, as provided by us.

Supplement A: EU Data Subjects’ Privacy Rights (GDPR)

If the European Union data protection laws applies to the processing of personal information related to you, this Supplement A is also relevant for you.

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  • If the European Union data protection laws apply to the processing of personal information related to you by SOSA, then, as of May 25, 2018, the following information, rights and obligations also apply.
  • We process personal information related to you for the following lawful grounds –
    • All processing of personal information related to you which are not based on the lawful grounds indicated below, are based on your consent.
    • We process your account and payment details to perform the contract with you.
    • We will process personal information related to you to comply with legal obligations and to protect your and others’ vital interests.
    • We will further rely on our legitimate interests, which we have good-faith belief that they are not overridden by your fundamental rights and freedoms, for the following purposes –
      • Communications with you, including direct marketing where you are our client, or a user of our client, or where you contact us or show interest in our services through our Site and other digital assets.
      • Cyber security.
      • Support, customer relations, service operations.
      • Enhancements and improvements to your and other users’ experience with our services.
      • Fraud detection and misuse of our services.
    • In addition to your rights under other sections in this privacy policy, you have the following rights –
      • Contact us if you want to withdraw your consent to the processing of personal information related to you. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
      • Request to delete or restrict access to personal information related to you. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
      • If you exercise one or more of the above-mentioned rights, in accordance with the provisions of applicable law, you can request to be informed that third parties that hold personal information related to you, in accordance with this privacy policy, will act accordingly.
      • You can ask to transfer personal information related to you in accordance with your right to data portability.
      • You can object to the processing of personal information related to you for direct marketing purposes. Additional information about this right is available under the Choice section in this privacy policy.
      • You have the right not to be subject to a decision which is based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affecting you.
      • You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
      • A summary and further details about your rights under the European Union data protection laws, is available on the European Union Commission’s website: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
      • Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will ask you further questions to understand the nature and scope of your request.
      • If we need to delete personal information related to you following your request, it will take some time until we completely delete residual copies of personal information related to you from our active servers and our backup systems.
    • We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this privacy policy, update the privacy policy when we believe that we need to, and verify that we display the privacy policy properly and in an accessible manner.
    • If you have any concerns about the way we process personal information related to you, you are welcome to contact our data protection team at Info@sosa.co. We will investigate your inquiry and make good-faith efforts to resolve any existing or potential dispute with you.
    • You are welcome to contact our representative in the European Union which is contact details are as follows: Rickert Rechtsanwaltsgesellschaft mbH, Kaiserplatz 7-9, 53225 Bonn, Germany; email address: datenschutz@rickert.net.

 

SOSA Cookies Policy

This cookies policy (this “Policy”) provides you with general information about cookies and similar technologies (collectively, “Tracking Technologies”) as well as how and for what purposes SOSA HOLDINGS LTD., Reg. No. 514620103 and its affiliates (“SOSA”, “we”, “us” or “our”) use such Tracking Technologies on SOSA’s website and landing pages (collectively, this “Website”).

Please take the time to read this Policy. If you have questions or comments, you are welcome to contact us at: info@sosa.co.

  • What Are ‘Cookies’

What Are ‘Cookies’?

Cookies are small files with pieces of information, normally consisting of just letters and numbers, which websites use when users visit them.

Software on the users’ devices (for example, a web browser) can store cookies and send them back to the website the next time they visit, to make a specific function of the website work and to provide information about the user’s activities on the website.

How Are Cookies Used?

Cookies are used in numerous ways. For example, when analyzing traffic to a website or tracking users’ browsing behavior.

Cookies are widely used because they allow a website to recognize a user’s device. Cookies and other similar technologies help websites to remember the visitors and their activities, for example, if they are logged in or added a product to the online shopping cart.

What Are ‘Session’ and ‘Persistent’ Cookies?

“Session Cookies” are removed from your computer once you close your browser session.

“Persistent Cookies” last for longer periods on your computer – after you close your browser session.

A user can delete previously set persistent cookies manually or configure the browser settings to delete cookies, as further described below.

What Are ‘First-party’ and ‘Third-party’ Cookies?

First-party cookies are set directly by the website that the user is visiting. For the purpose of this Policy, these are cookies that are set directly by this Website.

Third-party cookies are set by a domain other than the one visited by the user. For the purpose of this Policy, these are cookies that are set by service providers of this Website.

What Are ‘Similar Technologies’?

Functions usually performed by a cookie can be achieved by other means. This could include, for example, using certain characteristics to identify devices so that visits to a website can be analyzed.

Any technology that stores or accesses information on the user’s device is relevant for this purpose, and therefore it includes, for example, HTML5 local storage, Local Shared Objects and fingerprinting techniques.

Additionally, technologies like scripts, tracking pixels and plugins, wherever these are used – are also considered as similar technologies. For example, many companies, including us, conduct electronic marketing and incorporate a tracking pixel in email messages. The pixels record information including the time, location and operating system of the device used to read the email.

Does SOSA Use Tracking Technologies?

Yes, we do.

We use both Session Cookies and Persistent Cookies as part of your experience on this Website so that we can facilitate the use of the data’s features and tools, keep track of your preferences as well as improve our service.

Some cookies are strictly essential for the operation of this Website while other cookies help to improve our services and marketing activities. The same rule goes for all Tracking Technologies that we use.

We have created a detailed Tracking Technologies table page, which is attached as an Appendix A to this policy and is available here. The table will provide you with a clear and comprehensive image of the Tracking Technologies that we use.

When a Tracking Technology contains personal data, as indicated in Appendix A, our Privacy Policy applies as well.

Does SOSA Need to Obtain My Consent for Using Tracking Technologies?

Yes, however only with respect to the Tracking Technologies that are not strictly essential for the operation of this Website, as further indicated in Appendix A.

If you do not agree to accept our cookies or other Tracking Technologies that are not strictly essential for the operation of this Website, we will make commercially reasonable efforts to provide you with the same level of services.

Can I Manage My Tracking Technologies Preferences?

Every browser allows you to manage your Tracking Technologies preferences, usually found in the “Help” or “Settings” sections of the web browser.

Here are some links to some commonly used web browsers: (a) Google Chrome; (b) Microsoft Edge; (c) Mozilla Firefox; (d) Microsoft Internet Explorer; (e) Opera; (f) Apple Safari.

In addition, you can turn off certain third party targeting or advertising cookies by visiting the following link: Network Advertising Initiative.

To find out more about cookies, including how to see what cookies have been set, you can visit the following websites: www.aboutcookies.org and www.allaboutcookies.org.

Some web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference for tracking your activities on our services or through cross-site user tracking. This Website and services do not respond to DNT signals.

Will We Change This Policy?

We update this Policy, where needed. Every time we change this Policy, we either send you an email about it or post a notice on this Website. We will post a notice on this Website if our policy update includes substantial changes and obtain your consent once again, where required under applicable laws.

Appendix A: Tracking Technologies Table

Strictly Essential Cookies

These cookies are strictly essential for enabling your movement around this Website and providing access to features such as your profile and purchases, member-only services, and other secure areas of this Website. This category of cookies cannot be disabled.

Name Purpose & Expiration Date First/Third Party Cookie
_hs_opt_out This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies. It contains the string “yes” or “no”. Expiring after 13 months. First party
_hs_initial_opt_in This cookie is used to prevent the banner from always displaying when visitors are browsing in strict mode.
It contains the string “yes” or “no”. Expiring after 7 days.
First party

 

_deco_utm_referrer Tracks referring pages. Expiring after 2 months. First party
ubpv, ubrs, ubvs, ubvt These cookies are essential for the performance and the availability of SOSA’s landing page platform and are facilitated by https://www.unbounce.com First party

Analytics Cookies

Analytics cookies collect information about how visitors use this Website. Our service providers can transfer relevant information to third parties where required by law or where such third parties process such information on their behalf.

Name Purpose & Expiration Date and Opt-Out First/Third Party Cookie
_hssc This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. Expiring after 30 minutes. First party
_hssrc Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session. It contains the value “1” when present. It expires at the end of the session. This is a session based cookie. First party
_hstc The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). Expiring after 13 months. First party
Hubspotutk This cookie keeps track of a visitor’s identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor. Expiring after 13 months. First party
_gat_UA-88902366-1 Used by Google Analytics to distinguish users and sessions. Read more here. Expiring after 1 day. Opt out at: https://tools.google.com/dlpage/gaoptout/ First party
_gat Used by Google Analytics to distinguish users and sessions. Read more here. Expiring after 1 day. Opt out at: https://tools.google.com/dlpage/gaoptout/ First party
_ga Used by Google Analytics to distinguish users and sessions. Read more here. Expiring after 2 years. Opt out at: https://tools.google.com/dlpage/gaoptout/ First party
_gid Used by Google Analytics to distinguish users and sessions. Read more here. Expiring after 24 hours. Opt out at: https://tools.google.com/dlpage/gaoptout/ First party
_hjid Hotjar cookie. This cookie is set when the customer first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID. Expiring after 365 days. Opt out at: https://www.hotjar.com/privacy/do-not-track/ First party
_hjIncludedInSample Hotjar cookie. This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate funnels. Expiring after 365 days. Opt out at: https://www.hotjar.com/privacy/do-not-track/ First party
_hjAbsoluteSessionInProgress The cookie is set so Hotjar can track the beginning of the user’s journey for a total session count. It does not contain any identifiable information. Expiring after 30 minutes. Opt out at: https://www.hotjar.com/privacy/do-not-track/ First party

Marketing Cookies

Marketing cookies collect personal information such as your name, which pages you visit on this Website, your history arriving at this Website, your purchases from us, and so on. Collected information is used to evaluate and improve the effectiveness of our marketing campaigns.

Name Purpose & Expiration Date First/Third Party Cookie
_fbp Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. Expiring after 3 months. Opt out details at: https://www.facebook.com/help/568137493302217 First party
Google cookies Google Ads and remarketing services. Opt out at: https://policies.google.com/technologies/managing Third party
Facebook cookies Facebook ads and remarketing services. Opt out at: https://www.facebook.com/help/568137493302217 Third party
Linkedin cookies Linkedin ads and remarketing services. Opt out at: https://www.linkedin.com/legal/cookie-policy Third party

This Policy was last updated on May 27, 2020.