ESSENCE WEBSITE PRIVACY NOTICE

Last updated: August 21, 2024 

This Privacy Notice is incorporated by reference into the company website.  

In this Privacy Notice, we refer to Essence Security International Ltd. (ESI),Essence SmartCare  (ESC) Ltd. and Essence Interactive Center (EIC), and their subsidiaries and associated companies as “we” or “us” or “our”, and we refer to you as “you” or “your”. 

We are the data controller for the data practices explained in this Privacy Notice. 

We comply with applicable data privacy and protection law. This means that when processing personal information for any purpose we must ensure it is: 

1.How We Collect Information, for What Purposes and Our Legal Basis for It 

This Privacy Notice is designed to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive when you do any of the following (“Relevant Services”):  

• Visit the Essence website at www.essence-grp.com (the “Site”) 
• Fill out a contact form for the purposes of technical or other support or to inquire regarding business opportunities 
• Willingly provide your personal information for the purposes of a current or potential business engagement  

1.1 The Personal Information we collect 

In the course of using the Relevant Services, we ask you to provide us with certain personal information (“Personal Information”). 

Personal Information includes, your name, contact details and professional details and the content of your inquiry. 

We use this data to provide the Relevant Services. You are not legally obligated to provide us your information. You provide the information at your discretion. However, the information that we collect from you is required for us to provide you with the Relevant Services and we cannot provide the Relevant Services to you without processing your information.  

Our legal basis for processing this data is our legitimate interest: it is necessary to collect and retain this information for the purposes of managing our business relationships, or pursuing a potential business relationship with you.  

We also process statistical analytics information about your use of the Relevant Services, such as general behavior patterns, IP address (and the general location corresponding to the address), time and date of access, type of browser used, language use, links clicked, and the web pages you accessed.  

Our legal basis for processing this data is our legitimate interests in the proper operation of the company website. 

We do not knowingly collect personal information from children under the age of 18.     

1.2 Third Parties Receiving Information and International Data Flows 

Some of our services rely on third parties with whom we share some user information for the purpose of providing and maintaining these services to our users.   

These third parties include service providers that are authorized to use your personal information only as necessary to provide these services to us and our users, and not for their own promotional purposes. A list of these service providers is available at this link. 

We do not rent or sell your information to any third party. 

Any transfer of data outside your region to any third party service provider is done only to countries with adequate data protection, as defined by relevant regulations. 

Our services may be accessed internationally by us for the purpose of day to day use or service maintenance. 

We will disclose any information obtained by us –  

• If required by law or by any governmental authority. Our legal basis for this processing is our legitimate interests in complying with mandatory legal requirements imposed on us.  
• In case of emergency. Our legal basis for this processing is our legitimate interests in helping to protect property or well-being threatened by the emergency;  
• To a successor entity in connection with a merger, acquisition, bankruptcy, or sale of all or substantially all of our assets. Our legal basis for this processing is our legitimate interests in our business continuity.

1.3 Methods and sources for collecting your personal information; Retention Period  

We collect the personal information from several sources: 

• Directly from you as when you provide it to us through email communications, a registration form, or when you give us your business card. 
• If another representative of your organization provides us with your information  
• Through the device you use to access our Site, such as when we use cookies.  

We will retain your personal information for as long as you use the Relevant Service, and for a period afterward, as dictated by a reasonable backup policy and any relevant regulations.  

1.4 Security 

We are concerned with safeguarding your information. We employ a variety of organizational and technical security measures designed to protect your information from unauthorized access and disclosure.  

Your information is protected, in compliance with ISO 27001 standards, using state of the art technical security measures, such as: 

• Encryption and authentication mechanisms 
• Regular threat and vulnerability assessment 
• Physical site security  

We also take various organizational measures to ensure data security, such as: 

• Lawful data processing reviews 
• Privacy impact assessments 

We cannot guarantee that your personal information or private communications will always remain private and secure. We are obliged to notify you of any security breach resulting in high risk of private data exposure.  

1.5 Cookie Policy 

Like many websites and applications, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer or mobile device for record-keeping purposes. We use a website add-on tool to inform you of the types of cookies we use, their purposes, and their duration and to enable you to control the use of cookies and decide which cookies you agree to accept. However, you cannot disable the ‘necessary’ cookies through the add-on tool because the website cannot operate without them. You can set your browser to block these cookies, but some parts of the Site may not function properly. 

2. Contacting Us 

If you have any concerns or questions about this Privacy Notice or would like to lodge a complaint, please contact our data protection officer or our EU representative at +972 (0)73 2447777, DPO@essence-grp.com. 

3.   Information under state privacy laws in the United States 

This is the information we have collected in the past 12 months about consumers using our Relevant Services

Categories of Personal Information	Specific Types of Personal Information Collected	Source of Information
Identifiers	Name, contact details	The user themselves
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual	The content of your message to us	The user themselves
Internet or other electronic network activity information	Your usage patterns of the Relevant Services, IP address (and the general location corresponding to the address), time and date of access, type of browser used, language use, links clicked, and the web pages you accessed	The user’s device
Professional information	professional details	The user themselves

The following are the business or commercial purposes for which we use each category of personal information. Details about the information we collect for each category are provided in the table above.

Categories of Personal Information	Business or commercial purposes	Specific purposes
Identifiers	Providing customer service, processing, or fulfilling orders and transactions, verifying customer information Auditing relating to a current transaction with the customer	To provide our products and services   To verify your identity   To communicate with you  To improve our products and services and prevent fraud To receive feedback from you and inquire about any features you would like to see in future products and to promote new products or services Analyze our user database to review preferences and trends for our own internal statistical and analytical purposes
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual
Professional information
Internet or other electronic network activity information	Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, prosecuting those responsible for that activity Undertaking internal research for technological development and demonstration Undertaking activities to verify or maintain the quality of the service and to improve, upgrade or enhance the service Debugging to identify and repair errors

Please note that we do not sell your data and we have not done so in the preceding 12 months. We also do not share your data for cross-context behavioral advertising, and we have not done so in the preceding 12 months. 

We do not use or disclose sensitive personal information

The chart below explains the personal information we disclosed for a business purpose to third parties in the preceding 12 months.

Categories of personal information	Categories of third parties to whom we disclose your information and the specific business or commercial purpose for the disclosure
Identifiers	With third parties to which a law or binding order requires us to disclose your information to. Our purpose in doing so is complying with our obligations under the law or the binding order.  With the target entity of our merger, acquisition or reorganization, and legal counsels, and advisors, for the purpose of facilitating the structural change in the operation of our business within a different framework, or through another legal structure or entity (such as due to a merger or acquisition).
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual
Professional information
Internet or other electronic network activity information

YOUR RIGHTS UNDER STATE PRIVACY LAWS IN THE UNITED STATES

Disclosure of Personal Information We Collect About You	You have the right to know:  The categories of personal information we have collected about you. The categories of sources from which the personal information is collected.  Our business or commercial purpose for collecting personal information.  The categories of third parties with whom we share personal information, if any.  The specific pieces of personal information we have collected about you.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and  Direct any service providers to delete your personal information from their records.  Please note that we may not delete your personal information if it is necessary to:  Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us. Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.  Debug to identify and repair errors that impair existing intended functionality.  Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.  Comply with the California Electronic Communications Privacy Act.  Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.  Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.. or  Comply with an existing legal obligation. We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the CPRA applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.
Right to correct information	If we receive a verifiable request from you to correct your information and we determined the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you. In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information. We also may require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.  We may deny your request to correct in the following cases:  We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive. We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances. Conflict with federal or state law. Other exception to state privacy laws. Inadequacy in the required documentation Compliance proves impossible or involves disproportionate effort.  We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under state privacy laws. This means we cannot, among other things: Deny goods or services to you. Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.  Provide a different level or quality of goods or services to you. or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Designate an authorized agent to submit requests on your behalf	You may designate an authorized agent to make a request on your behalf. To do so, you need to provide the authorized agent written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.

If you would like to exercise any of your CCPA rights as described above, you should either:

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of your request.

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