CORTOX PRIVACY POLICY

Effective Date: July 1, 2023

This privacy policy (the “Policy”) is an integral part of the Cortox Terms of Use (the “Agreement”). All the terms used herein are used with the same meanings as the Agreement provides unless otherwise are directly set out hereby.

We are deeply committed to safeguarding and respecting your privacy. Therefore, we handle your personal data (referred to as the "data") with utmost seriousness and use it solely to ensure the availability of the Website and process the requests you send us. We will collect and process your data only after obtaining your explicit consent, as detailed in the Policy below.

Our Privacy Policy outlines the specifics of what data we collect from you, when and where it is collected, the reasons for its collection, the legal basis for processing your data, how we utilize it, the circumstances under which we may share your data with others, your rights concerning your personal information, and the measures we take to ensure its security.

As tracking technologies, such as cookies, are utilized on the Website, we kindly request you to review our Cookies Policy. In this policy, we explain the purpose and means by which we employ these technologies.

Rest assured that your privacy is our priority, and we are committed to maintaining the highest standards in protecting your personal data.

If you have any questions, please contact us:

Cortox Limited, Pavlou Nirvana, 4 ALPHA TOWER, 1st floor, Flat/Office 13 3021, Limassol, Cyprus
Email: info@cortox.org.

CHANGES TO THIS POLICY

We reserve the right to revise the Policy in response to new developments or changes in legislation and the wider data protection environment. It is advisable to check this page periodically to ensure that you are comfortable with any modifications made to the Policy.

1. In the event of any material changes to the Policy, we will notify you via email to the address you have provided. For other non-material changes, we will inform you by publishing the updates on the Website CORTOX.ORG.

DATA CONTROLLER AND DATA PROCESSORS; THIRD PARTIES

The first important piece of information you should know is about the data controller and data processors. The data controller is the entity responsible for determining the purposes and means of processing your data. On the other hand, the data processor is an entity that processes your data on behalf of the data controller.

In this current case, your data controller is Cortox Limited.

1. When processing your data, we may use the following data processors:

G-Suite service which may be represented by Google LLC (California, USA), Google Ireland Limited (the Republic of Ireland), Google Asia Pacific Pte. Ltd. (Singapore), or any other entity that directly or indirectly controls, is controlled by, or is under common control with Google LLC, which is storage place provider, in order to store the data. Google provides more information on how it processes data in its Privacy Policy;
Google Analytics services which may be represented by Google LLC (California, USA), Google Ireland Limited (the Republic of Ireland), Google Asia Pacific Pte. Ltd. (Singapore), or any other entity that directly or indirectly controls, is controlled by, or is under common control with Google LLC, which is analytical services provider, in order to analyze the data. Google provides more information on how it processes data in its Privacy Policy;

1. In certain instances, we may require the assistance of third-party services and may share your data with them. This is essential to facilitate the operation, improvement, integration, customization, support, and marketing of our services and the Website. The data is shared, primarily for the purposes outlined in section 5 of this Policy. The types of third parties with whom we share information include, but are not limited to, cloud storage providers, data analytics providers, measurement partners, marketing partners, payment processing providers, communication services providers, and others. It is important to note that by providing us with their services, these third-party providers also act as data processors for your data.

1. Additionally, we may use and disclose your data to enforce the Agreement, safeguard our rights, privacy, safety, or property, as well as that of our affiliates, you, or others. This includes responding to requests from courts, law enforcement agencies, regulatory bodies, and other public and government authorities, or as required by law in other circumstances.

1. If we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission, or (ii) the European Commission adequacy decisions about certain countries (details available here).

CHILDREN RIGHTS

The use of the Website is strictly prohibited for individuals who are under 18 years of age or who have not reached the age of legal majority in their country. We do not knowingly process personal data from individuals under 18 years of age.

1. In the event that a minor submits personal information to us, and we become aware that the information belongs to a child under the legal age range, we will make every effort to promptly delete such information. If you suspect that we may possess any personal information of a child under the legal age range, please contact us at [contact email/number]. We take this matter seriously and will take necessary steps to address it promptly info@cortox.org .

CATEGORIES OF DATA THAT WE PROCESSES

The term "data" refers to any information related to you, which, either alone or when combined with other information, enables the entity that collected and processed such data to identify you as an individual. "Processing of the data" encompasses any action taken with your data, including but not limited to collecting, storing, transferring, and more.

1. We, either independently or with the assistance of data processors, may collect the following data about you:

the data we receive when you contact us: preferred language of communication, name; email; any information included in the inquiry;
the data we receive when you use the Website, including, without limitation: duration of a session; the history of the interaction of the Website; surveys responses, data you provided our support team with, including, the language of your requests; other information you may voluntarily provide us with whether by adding in your profile or sending us direct messages;
the data we collect automatically: data about how you found us; IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, country, region, city; your activity on the Website;
cookies and other tracking identifiers as our Cookies Policy set forth;

PURPOSES AND LEGAL BASSES OF DATA PROCESSING

We process your information with the following purposes:

To enable the accessibility of the Website for you and provide you with the most relevant services associated with the Website;
To communicate with you regarding your usage of the Website, address your requests, provide updates on services, information, and products;
To inform you about any critical information or changes within the Website that may impact your usage or experience;
To analyze the number of active users, offer support to users from different regions, ensure the proper functioning of various versions of the Website, and facilitate the development and optimization of the Website;
To maintain the safety and security of the Website, enforce the Agreement, and prevent and combat fraud;
To conduct statistical market studies and analysis;
To fulfill our legal obligations.

1. We may also send you news and information about us and the Website, either as per your request or if we believe it may be of interest to you. In most cases, we will contact you via email.

1. We process your data under the following legal bases:

performing of the contract (the Agreement) with you: a) to make the Website available for your access as well as provide you with the most relevant services with the Website; b) to communicate with you regarding your use of the Website, your requests, update you on services, information, and products; c) to notify you of any crucial information or changes within the Website which may affect you;
our legitimate interest: a) to send to you marketing communications; b) to analyze active users’ number, support users from different regions and provide proper work of various versions of the Website as well as to develop and optimize the Website; c) to keep the Website safe and secure, enforce the Agreement and prevent and combat fraud; and d) to comply with our legal obligations.

1. Please be aware that when data is collected for marketing purposes, you will be asked for specific consent for such processing. Additionally, you will have the option to withdraw your consent at any time, free of charge. This can be done by clicking on a separate "Unsubscribe" button in the emails we send to you.

PROCESSING TERM AND LOCATION

Your data will be processed during the period of your usage of the Website and until the termination of such usage (or the Agreement), which includes the deletion, blocking, or suspension of your account on the Website. Upon termination, we will cease processing your personal information, unless specific retention periods are mandated by relevant legislation. In such cases, the data will be retained in accordance with the prescribed legal requirements.

1. You have the right to restrict us from processing your data by sending a data erasure request or a notice prohibiting the processing of your data. It is important to understand that such action will prevent us from processing your data and may result in the deletion of your data, which could lead to a loss of access to the Website. Furthermore, it may restrict our ability to respond to your inquiries.

1. Your personal information is stored by Wix.com Ltd. in Israel, which the European Commission considers as a country offering an adequate level of protection for the Personal Information of E.U. Member State residents. WIX is a provider that is in charge of security means implemented and you could familiarize yourself with their security practices in the relevant Privacy Policy.

TRACKING TECHNOLOGIES

We utilize cookies and other tracking technologies to enhance your user experience and gather data about the usage of the Website. This data enables us to develop and optimize the Website. For further information, please refer to our Cookies Policy to learn more about how we use cookies and tracking technologies.

YOUR DATA SUBJECT’S RIGHTS

Being a data subject, you have the following rights:

a right to request us to access to your data: you can ask us what personal information of yours is being processed as well as for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties that have access to information. To exercise the right please contact us at info@cortox.org;
a right to request us to rectify your personal information: you can ask all the inaccurate personal information concerning you being corrected. You can also complete the personal information if you feel there is a need to do so. To exercise the right please contact us at info@cortox.org or use a specific area of your account on the Website;
a right to request us to erase personal information: you can request us to erase such data if its processing is no longer necessary in relation to the purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases we will erase it unless otherwise will be required by legislation. To exercise the right please contact us at info@cortox.org;
a right to request us to restrict the processing of your data: for example if you contest the accuracy of your data being processed or in case we will not be interested to process your personal information any longer, but you will want us to do this on different reasons, for example, to bring some claim for somebody and instead of the erasure of information its processing will be just restricted. To exercise the right please contact us at info@cortox.org;
a right to withdraw your consent for the collection and processing of your data by us at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To exercise the right please contact us at info@cortox.org;
a right to lodge a complaint with supervisory authority; and
a right to data portability. To exercise the right please contact us at info@cortox.org.

1. We will respond to your request regarding your rights specified above and provide information on the action taken within one month from the receipt of the request at the longest. However, if we receive an overwhelming number of requests, the response time may be extended by an additional two months. In such cases, we will inform you of any extension within one month from the receipt of the request, along with the reasons for the delay.

DATA PROTECTION

We implement technical and organizational measures to ensure the secure processing of information, including protection against unauthorized or unlawful processing, as well as accidental loss, destruction, or damage. For instance, we engage verified contractors who may have access to the data as specified in section 4 of this Policy. We ensure that relevant data processing agreements are signed with these contractors to maintain the security and confidentiality of your data.

We will be glad to hear something from you. If you have any questions regarding this Policy, please contact us at:

Cortox Limited, Pavlou Nirvana, 4 ALPHA TOWER, 1st floor, Flat/Office 13 3021, Limassol, Cyprus
Email: info@cortox.org.

Last updated: July 1st, 2023