Effective date: 01 July 2023
II. General Information
Who is the data controller? Unless otherwise stated in a service-specific privacy notice, the data controllers responsible for processing your information collected in the context of using this website are Sapiens Technologies (1982) Ltd, registered office address at Azrieli Center, POB 1753, 26 Harokmim street, Holon, Israel 5885800 and its subsidiaries. The Sapiens entity responsible for the processing of your personal data thus depends on which entity you are working with. This policy applies to such entity.
Where a registration form is presented on this website or data is collected in a context of specific activity, the data controller may vary depending on the actual offering or the purpose of the data collection, but it is in any case displayed on the individual registration form’s privacy statement.
What type of information we collect
- Contact details such as name, address, e-mail and telephone number.
- User information, such as IP number, browser information, information about the device you are using, and also information on how to interact with our services, such as the features you use.
- Other information we receive from you through your contact with us.
- The information you may have made publicly available via settings at e.g. Facebook, Instagram and LinkedIn.
For what purposes we use data
- Providing our services in accordance with applicable contractual terms.
Legal grounds: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you), consent, legal obligation
- Developing and improving our services.
Legal grounds: legitimate interests, consent
- Managing our relationship with customers and contacts.
Legal grounds: contract performance, legitimate interests, consent
- Sending newsletters for the recipients who have chosen to sign up to receive such communications.
Legal grounds: legitimate interests, consent
- Recording your registration to Sapiens events for administration purposes.
Legal grounds: contract performance, legitimate interests, consent, legal obligation
- Image branding of Sapiens and marketing of our products.
Legal grounds: legitimate interests, consent
- Providing you with a better website experience and collecting information on website statistics.
Legal grounds: legitimate interests, consent
What is the legal basis of processing:
We will only use your personal data only where we are permitted to do so by law. Under EU and UK data protection regulations, the use of personal data must be justified by a legal basis. The principal legal grounds that we use to process personal data are:
- Contract performance: where your information is necessary to enter into or perform our contract with you.
- Legal obligation: where we need to use your information to comply with our legal obligations.
- Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
- Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).
How long will Sapiens store personal data Sapiens will only store your personal data for as long as it is required:
- to make goods and services requested available to you, including use of sapiens.com;
- for Sapiens to comply with its statutory obligations resulting inter alia from applicable export laws;
- until you object against such use by Sapiens, if Sapiens’ use of your personal data is based on Sapiens’ legitimate business interest as further stated in this Privacy Statement;
- until you revoke your consent granted in this Privacy Statement, if Sapiens is processing your personal data based on your consent
Sapiens will also retain your personal data for additional periods if it is required by mandatory law to retain your personal data longer or where your personal data is required for Sapiens to assert or defend against legal claims. Sapiens will retain your personal data until the end of the relevant retention period or until the claims in question have been settled. Sapiens will delete your personal data after the purpose has ceased to exist or after the expiry of the respective retention period.
How we share data
We do not share your personal information with companies, organizations, or individuals outside of Sapiens except in the following cases:
- companies within the Sapiens group,
- third-party service providers; in particular providing consulting services, plugins and services used on the website and in the newsletters, online advertising and other additional related services.
In certain situations, your personal data may be transferred to a country outside of the EU/EEA. Sapiens ensures that such transfer(s) will be carried out in accordance with the applicable data protection legislation. Such transfer may only take place if we ensure an adequate level of data protection either by ensuring that the recipient enters the EU Commission’s standard contractual clauses with Sapiens or if the country has adequate data protection standards confirmed by the EU Commission’s decision.
Cookies contain a so-called cookie ID. This ID can be used to identify an Internet browser when it is used to call up the website again. In the long term, we can evaluate their movements on the website and thus improve them.
You can also deactivate the storage of cookies in your browser. You will find instructions on how to do this in the help section of your browser.
- Necessary cookies, which are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
- Functional cookies, which help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
- Performance cookies, which are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
- Analytical cookies, which are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
- Advertisement cookies, which are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
IV. Privacy controls
Your data protection rights:
- right to obtain confirmation/ right to be informed: In order to exercise its right of confirmation of the processing concerned, the data subject may at any time turn to our Data Protection Officer or to any other employee of the controller.
- right of access by the data subject: : We provide free information at any time about the data stored about a person. We also provide information on the following issues:
- the processing purposes
- the categories of personal data
- the recipients or categories of recipients to whom the personal data have been disclosed, in particular recipients in third countries or international organisations
- where possible, the planned duration for which the data will be stored, or the criteria for determining that duration
- with regard to the right to correct or delete personal data concerning that person or to restrict the processing or the right of opposition to such processing
- with regard to the right of appeal to the competent supervisory authority
- all available information about the origin of the data
- the existence of automated decision-making, including profiling (Articles 22 (1) and (4) of the GDPR) including the logic involved and the scope and impact on the person concerned
3. right to correction: You have the right to have inaccurate personal data concerning you corrected. Furthermore, you may request the completion of incomplete data.
4. right to erasure (right to be forgotten): You have a right to request deletion of your data processed by us if one of the following reasons applies and processing is not necessary:
- The purpose of the data collection has ceased to exist.
- You revoke your consent in accordance with Article 6 (1)(a) of the GDPR or Article 9 (2)(a) of the GDPR, and there is no other legal basis for processing.
- You file an objection pursuant to Art. 21 para. 1 GDPR and there are no primordial legitimate grounds for processing, or the data subject lodges an objection against processing pursuant to Art. 21 para. 2 GDPR.
- The data have been processed without legal basis.
- The deletion of data is necessary for the fulfilment of a legal obligation.
- The personal data were collected in relation to the information society services offered in accordance with Art. 8 para. 1 GDPR.
5. right to restrict processing: You have the right to restrict the processing of your data under the following conditions:
- You deny the accuracy of the data and allow us sufficient time to verify this.
- Processing is unlawful, but they refuse to delete personal data and instead demand that the use of the data be restricted.
- We no longer need the data for the original purposes, but they do need the data for asserting, exercising or defending legal claims.
- You have lodged an objection against the processing in accordance with Art. 21 para. 1 GDPR and it is still unclear whether our legitimate reasons outweigh their grounds.
6. right to data portability: You have the right to receive all data stored by us in a common format from us. You also have the right to transmit this data to another person in charge without hindrance by us, provided that the legal basis of the processing is correct (art. 6 par. 1 or art. 9 par. 2 GDPR) and the processing is carried out by means of automated procedures and is not necessary for the fulfilment of a task that is in the public interest or in the exercise of official authority. In addition, you can also arrange for personal data to be transferred directly from us to another person in charge, insofar as this is feasible and insofar as this does not affect the rights and freedoms of others.
7. right to object: You have the right to object at any time to the processing of your data on the basis of your personal situation, which is carried out on the basis of Art. 6 para. 1 letter e or f GDPR. In this case, we will no longer process your personal data unless we have legitimate grounds for processing that outweigh your interests or the processing serves to enforce legal claims. You have the right to object at any time to the processing of your personal data for advertising purposes and, if applicable, to profiling in connection with such advertising. Depending on their personal situation, they may object to the use of data that could be used by Sapiens for scientific research purposes or for other purposes in accordance with Article 89 (1) GDPR, provided that such fulfilment of one is in the public interest.
8. rights in relation to automated decisions in individual cases including profiling: You may object to the use of your data for the purpose of making automated case-by-case decisions (including profiling), provided that this decision would have legal effect or would otherwise affect them. Insofar as this is necessary for the performance of a contract between them and us, or if this is required by law or expressly approved by us, this right shall not apply. If the decision to fulfil the contract or with its consent is made, Sapiens shall take appropriate measures to protect its rights and freedoms. This includes at least the right of Sapiens to intervene on the part of a person and to present their position and to challenge the decision.
9. Right to revoke consent under data protection law: You may revoke your consent to the processing of your personal data at any time.
How to exercise your rights Please direct any requests to exercise your rights to firstname.lastname@example.org.
How to contact us Any person concerned may contact the Data Protection Officer of Sapiens for all questions relating to data protection: E-mail: email@example.com
V. Additional Disclosures for California Residents This section is related to the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA).
Sapiens is mainly acting as “service provider” (as defined in the CCPA) and as such, the below does not apply. When acting as a service provider we confirm that processing (as defined in the CCPA) of Personal Information defined in the CCPA in connection with its performance under any contract executed with a customer, acting as a “business” (as defined in the CCCPA), only will occur on behalf of the business and for the benefit of the business from which it has received the personal information, in accordance with the business’s written instructions, and only for the purpose set out in the contract.
When we are acting as “business” under CCPA, mainly when you are using our website or are interacting with our pages on social media, the below applies:
As a business covered by the CCPA, we do not sell Personal Information. We may share Personal Information (in the form of identifiers and internet activity information) with third party advertisers for purposes of targeting advertisements on non-Sapiens’ websites. In addition, we may allow third parties to collect Personal Information from our website based on your cookies’ choice, or if you direct us to disclose your Personal Information to third parties.
California law requires that we detail the categories of Personal Information that we disclose for certain “business purposes,” such as to a third-party service provider. In the preceding 12 months we have disclosed the following categories of Personal Information for our business purposes to service providers that for example assist us with marketing our products, as further described in Section II of Sapiens Privacy Statement:
- Personal Identifiers.
- Information collected by cookies and other technologies, including IP address.
- Internet or other electronic network activity information.
For information on how to exercise your rights, please refer to Section IV of this Privacy Statement. If you are an authorized agent wishing to exercise rights on behalf of a California resident, please contact us using the information in the “How to exercise your rights” section above and provide us with a copy of the consumer’s written authorization designating you as their agent. If you would like to opt-out of sharing, please contact us using the information in the “How to exercise your rights” section above.
We may need to verify your identity and place of residence before completing your rights request.
VI. Changes to this policy