MANTIS VISION PRIVACY POLICY

This privacy policy (“Privacy Policy”) governs how we, Mantis Vision Ltd. (together, “Mantis Vision” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”, “you”) such as in the following use cases:

• When you make use of the our App Faceplant (“Faceplant“)
  1. When you download the app and use Faceplant
  2. When you capture a 3D face recording.
  3. When you plant (i.e., publish) a 3D face recording
• When you make use of the App Volume (“Volume“)
  1. When you download the app and use Volume
  2. When you cross a gate and receive a 3D body model capture (either body or object)
• When you browse or visit our website, http://mantis-vision.com/ (“Website”);
• When you make use of, or interact with, our Website
  1. When you subscribe to the email list / newsletters
  2. When we process your job application
  3. When you contact us (e.g. customer support or chat)
• When you attend a marketing event and provide Personal Data
• When you exchange business cards with us
• When we use the Personal Data of our service providers
• When we use the Personal Data of our customers
• When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn, etc) and we use the publicly available information

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. How we protect and store your Personal Data
3. How we share your Personal Data
4. Additional information regarding transfers of Personal Data
5. Your rights
6. Use by children
7. Public information about your activity on the services
8. How can I delete my account?
9. Links to and interaction with third party product
10. Log files
11. Cookies and other tracking technologies
12. Use of Analytics Tools
13. California privacy rights
14. Our California do not track notice
15. Deletion of content from California residents
16. How to contact us

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below.  If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

 

Data we collect	Why is the data collected and for what purposes?	Legal basis (GDPR only)			Third parties with whom we share your data		Consequences of not providing the data
When you make use of our App Faceplant (“Faceplant”)
When you download the app and use Faceplant
·        Phone number	·        User identification / authentication	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to perform the service of Faceplant)			Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd.		Cannot identify you
When you plant (i.e., publish) a 3D face recording
·        Face record (3D image and/or video)  ·        IP Address ·        Location of a point of planting ·        Geolocation ·        Faceplants you watch, either yours or other people	·        To plant a face in the public environment ·        To play and/or view and/or interact with images captured by you or other in the context of the Faceplant app	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to play with images captured by you in the context of the Faceplant app)			Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd.		Cannot plant a face in the public environment Cannot play and/or view and/or interact with images captured by you or other in the context of the Faceplant app
When you make use of the our App Volume (“Volume”)
When you download the app and use Volume
·        Phone number	User identification/ authentication	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to perform the service of Volumeplant)			Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd.		Cannot identify you
When you cross a gate and receive a 3D body model capture (either body or object)
·        3D body model capture (body or object). ·          The 3D model can be captured either static or dynamic by a set of cameras in the form of gateway or other setup. ·        Phone number	·        To receive a 3D body model capture static or dynamic ·        To enable you to have access and/or to see your 3D body model capture	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to perform the service)			Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd.		Cannot receive a 3D body model capture static or dynamic Cannot enable you to have access and/or to see your 3D body model capture
When you make use of, or interact with our Website
When you browse or visit our website
Cookies Read more in our cookie policy- [[add jump link to COOKIES AND OTHER TRACKING TECHNOLOGIES Below ]  ]	For user preferences and to improve the services	Legitimate interest (e.g. essential cookies)			3rd party platforms such as for the following purposes: ·        Active trail (marketing communications) ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd.		Cannot collect and store the information Cannot use or access some parts of the website
When you subscribe to the email list / newsletters
·        Full name ·        Email address ·        Any other data you decide to provide/supply	·        Adding you to our mailing list ·        Sending response and  other marketing communications	The data subject has given consent to the processing of his or her personal data for one or more specific purposes Legitimate interest (e.g. send you more information about Mantis Vision)		3rd party platforms such as for the following purposes: ·        Active trail (marketing communications) ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd.		Cannot add you to our mailing list Cannot send you marketing communications
When we process your job application
·        Full name ·        Email address ·        Phone number ·        CV ·        Any other data you decide to provide/supply	·        Process your job application ·        To assess the candidate	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to assess a candidate)		3rd party platforms such as for the following purposes: ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd. ·        Emails hosting (Microsoft)		Cannot process your job application Cannot assess your suitability as a candidate
When you contact us (e.g. customer support or chat)
·        Full name ·        Email address ·        Any other data you decide to provide/supply	·        Answer questions ·        Provide support	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. respond to a query sent by you)			3rd party platforms such as for the following purposes: ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd. ·        Emails hosting (Microsoft)		Cannot assist you and respond your query Cannot provide support
When you attend a marketing event and provide Personal Data
·        Full name ·        Email address ·        Company name ·        Any other data you decide to provide/supply	·        Establishing a business connection ·        Sending marketing communications		The data subject has given consent to the processing of his or her personal data for one or more specific purposes Legitimate interest (e.g. send you more information about Mantis Vision)		3rd party platforms such as for the following purposes: ·        Active trail (marketing communications) ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd.		Cannot establish a business connection   Cannot send you marketing communications
When you exchange business cards with us
·        Full name ·        Email address ·        Company name ·        Any other data you decide to provide/supply	·        Establishing a business connection		Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. showing you certain products and features that you have shown an interest in).   Legitimate interest (certain B2B marketing communications)		3rd party platforms such as for the following purposes: ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd. ·        Emails hosting (Microsoft)		Cannot establish a business connection
When we use the Personal Data of our service providers and suppliers
·        Full name ·        Email address ·        Company name and number ·        Phone number ·        Any other data you decide to provide/supply	·        To contact our service providers   ·        Processing the order of the service		Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract   Legitimate interest (e.g. perform the contract, send contract-related communications)		3rd party platforms such as for the following purposes: ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd. ·        Emails hosting (Microsoft)		Cannot communicate with you   Cannot process the order of the service
When we use the Personal Data of our customer
·        Full name ·        Email address ·        Company name ·        Phone number ·        Any other data you decide to provide/supply	·        Providing our services   ·        Performing the agreement		Processing is necessary for the performance of a contract to which our customer is a party.   Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).   Legitimate interest (e.g. send you contract-related communications)		3rd party platforms such as for the following purposes: ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd. ·        Emails hosting (Microsoft)		Cannot provide the services   Cannot communicate with you   Cannot perform the agreement
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn, etc.) and we use the publicly available information
·        Full name ·        Email address ·        Company name ·        Any other data you decide to provide/supply	·        Establishing a business connection		The data subject has given consent to the processing of his or her personal data for one or more specific purposes   Legitimate interest (e.g. send you more information about Mantis Vision)		3rd party platforms such as for the following purposes: ·        Active trail (marketing communications) ·        Mantis Vision Ltd will store the data in an internal cloud-based server which is run and managed by Mantis Vision Ltd. ·        Emails hosting (Microsoft)		Cannot establish a business connection

 

 

2. PERIOD OF STORAGE OF COLLECTED INFORMATION

The information we collect will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

3. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy [add jump link to COOKIES AND OTHER TRACKING TECHNOLOGIES

Below ] 

4. HOW WE PROTECT AND STORE YOUR INFORMATION

• Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

• Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

5. HOW YOUR PERSONAL INFORMATION IS SHARED

 

4.1 We share your information as follows:

In addition to the recipients described in Section 1, we may share your information as follows:

• To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
• If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
• Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
• Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
• We share the following information with other users and the general public of Faceplant: The content that you post or submissions to an essentially public service that are set to be viewable by the users and general public of Faceplant, as a face (3D image and/or video), and geolocation. This content may be viewed and shared by the public.

4.2 You may share your information as follows:

You may share the face (3D image and/or video) that you capture:

• With your family and friends using Third Party Services, and/or
• With users and the general public of Faceplant.

6. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

 

Access from Israel: It is covered by Israel’s Adequacy Decision and involves no data transfer issue. You can read more about this here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en  

 

Internal transfers: We ensure transfers within the Mantis Vision group will be covered by an agreement entered into by members of the Mantis Vision group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;

 

External transfers:

• Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.

• Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States; or

 

• Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

7. YOUR RIGHTS

 

The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

• You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.

• You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
• The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
• The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
• The right to withdraw your consent. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.

• You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us at Legal-notice@mantis-vision.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

8. USE BY CHILDREN

We do not offer our products or services for use by children under the age of thirteen (13) years. Accordingly, we do not intend to collect Personal Data from anyone we know to be under thirteen (13) years. If we learn that we have collected Personal Data from a child under thirteen (13) years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at Legal-notice@mantis-vision.com. If you are under thirteen (13), you may not use the App, or provide any information to the Website and/or App without involvement of a parent or a guardian.

9. PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICES

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Site or otherwise through the Services.

Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

 

Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

 

10. HOW CAN I DELETE MY ACCOUNT?

Should you ever decide to delete your Account, you may do so by emailing Legal-notice@mantis-vision.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

11. LOG FILES

We may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

12. COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Site may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

13. ANALYTIC TOOLS

Google Analytics. The Site may use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

14. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our subscribers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

 

15. OUR CALIFORNIA DO NOT TRACK NOTICE

 

We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

16. DELETION OF CONTENT FROM CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to Legal-notice@mantis-vision.com. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

 

17. CONTACT US

 

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at Legal-notice@mantis-vision.com.