This Privacy Policy governs the handling of Personal Data by O.I.J Orchestra Group Ltd. and all its affiliates (“Orchestra Group”, “we” or “us”) in the course of carrying on commercial activities, including when you visit our website, http://www.orchestragroup.com (the “Website“), and through your purchase or use of our products and services, including the Smart Protectors and the Orchestra Group Cloud Service also known as Harmony IoT (collectively, the “Services“).

O.I.J Orchestra Group Ltd. respects your right to privacy. To provide you relevant information, respond to your requests, and increase the benefits you receive when visiting our Website(s), we may collect personal information about you. However, we do not directly collect any Personal Data (as defined below) through our Services (as defined below).

“Personal Data” means any direct or indirect identifiers relating to natural persons, who can be identified from information which is in the possession of, or is likely to come into the possession of, Orchestra Group (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Orchestra Group or any other person in respect of natural persons.

Your use of our Website or your use any of our Services is subject to this Privacy Notice and our Terms of Use, including its applicable limitations on damages. The Terms of Use are incorporated by reference into this Privacy Notice.

1. THE TYPES OF PERSONAL DATA WE COLLECT

The Services offered by Orchestra Group do not require us to obtain any Personal Data about you. However, in the course of visiting our Website or by entering into business engagements with us, and in order to perform the Services we have been engaged to provide, we may obtain Personal Data about you:

• Information that you provide to us. This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
• basic Personal Data, such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country;
• any information that you choose to share with us which may be considered Personal Data;
• Information that we collect or generate about you through the Website.This includes (by way of non-exhaustive list) a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
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• When you visit our Website, analytical cookies are used to collect technical information about the services that you use, and how you use them.
• For more information on the cookies we used, please see our Cookies Notice.
• Anonymized data. In addition to the categories of Personal Data described above, we will also process further anonymized information and data that is not processed by reference to a specific individual, which may be collected or detected by our products and processed as part of the Orchestra Group Cloud Service

This Notice does not cover the practices of companies or organizations not owned or controlled by us that use our Services. Please refer to the relevant company’s privacy notice for information on how they handle your Personal Data.

2. HOW DO WE COLLECT PERSONAL DATA
   • We collect Personal Data directly from you when you:

• Request a quote, make a purchase;
• Complete an online registration form, request information or support, subscribe to our newsletters;
• Submit an inquiry or comments, including inquiries via this Website, email, direct mail, phone, fax, or on one of our social networking pages;
• Submit a request for product support;
• Apply for a job online;
• Otherwise contact us or use our Website or the Services.
  • The type of Personal Data that we collect from you will depend on your specific interaction with our Website and/or our Services, and may include: your first and last name, professional title, employer or company name, email address, mailing address, phone number, country/region, password and any other Personal Data that you choose to provide to us.
  • We do not collect personal data through our Services and in particular through our Smart Protectors. However, our Smart Protectors may collect certain data relating to device identifiers and localization information, on a de-identified or anonymized basis, which may be processed by our servers as part of the Services.
  • If you provide us feedback or contact us via e-mail (e.g., in response to an employment opportunity posted on our Website, or by sending us a question about our privacy practices), we will collect your name and e-mail address, so that we can reply, as well as any other content included in or provided with the email, such as a resume.
  • When you use our Website we automatically collect and record in our server logs the following information about your use of our Website through cookies, web beacons, and other technologies: usage data, IP address, web browser type/version, operating system and Website visit information such as date, time and pages viewed, language preferences, search engine keywords used and length of time on our Website. We also will collect click-through information related to our emails and banner advertisements, if any. Please see our Cookie Policyfor more information.
  • From time to time, we may receive Personal Data about you from third party sources like partners, resellers, analytics providers or companies that provide services (such as payment processing services in connection with our Website), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us.

Our resellers and companies that provide our Services through their online marketplace may supply us with personal data, such as your name, telephone, email, and business address to help us fulfil orders, and provide services and support. To enhance our ability to provide relevant marketing, information and offers about our Services to you, we may also obtain information about you from other sources such as public databases, social media platforms, joint marketing partners, as well as from other third parties.

We use the information we receive from these third parties to maintain and improve the accuracy of the records we hold about you, to help us establish an account or fulfil orders and provide services and support.

• Where permitted by applicable law, we may combine this data with other information we collect from and about you.

3. USE OF PERSONAL DATA
   • We use your information, including your Personal Data, for the following purposes:

• To provide our Services to you, to communicate with you about your use of our Services, to respond to your support needs and inquiries, and for other customer services purposes.
• For marketing and promotional purposes. In accordance with applicable law, we will use Personal Data, such as name, title, company, and email or other address, to communicate special promotions, events and announcements, including through email.
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Website.
• To better understand how users access and use our Website and our Services, both on an aggregated and individualized basis, to improve our Website and our Services, measure performance and activities on our Website, to improve the Website’s design and functionality, and for other research and analytical purposes, including research surveys.
• To investigate and prosecute suspected or actual security violations, violations of this policy, or our Terms of Use.
• For research and analytical purposes, including to assist us in evaluating and improving our Services and offerings.
• To protect our rights and our legitimate interests, such as:
  • allowing us to effectively and efficiently manage and administer the operation of our business;
  • maintaining compliance with internal policies and procedures;
  • monitoring the use of our copyrighted materials;
  • enabling quick and easy access to information on our products;
  • offering optimal, up-to-date security solutions for mobile devices and IT systems; and
  • obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market
• However, we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

• we need to do so in order to perform its contractual obligations with its customers;
• we have obtained your consent;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • We will use the Personal Data we collect from you for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your Personal Data.

4. PERSONAL DATA SHARING AND DISCLOSURE
   • We may share your Personal Data for the purposes described above.
   • We may also share your Personal Data outside of Orchestra Group for the following purposes:
     • With our business partners. For example, this could include our partners from whom you or your company or your organization purchased our product and Services. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
     • With third party agents and contractors for the purposes of providing services to us (for example, our accountants, professional advisors, IT and communication and marketing providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
     • To the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights; and
     • If we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes or if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.

5. DATA SECURITY

We use appropriate technical and organizational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. Specific measures we use include restricting access to staff on a need to know basis, encryption during transit and at rest, and use of anti-virus software and intrusion detection systems to protect against attacks or other unauthorized acts in respect of information systems.

6. INTERNATIONAL DATA TRANSFERS

We are a global business. Our customers and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

Our platform related to the Services, namely the Orchestra Group Cloud Service, is hosted in the cloud by an international service provider and the physical location of any personal data stored by such platform is restricted to the Republic of Ireland.

The personal data will be accessed from personnel in Israel. EEA visitors and customers should be aware that Israel was recognized by the European Commission as providing adequate protection to personal data in terms of Chapter V of the GDPR. The adequacy decision can be found here:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061

You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described below.

7. DATA RETENTION

We will hold your Personal Data for the purpose for which we are using it and will keep it for as long as is necessary for that purpose.

We may also hold your Personal Data for purposes of legal requirements based on our legitimate interests. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

8. YOUR DATA PROTECTION RIGHTS

In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to us;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
• the right to request that we restrict our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your Personal Data but we are legally entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details listed below

9. LEGAL BASIS FOR PROCESSING PERSONAL DATA (EEA VISITORS ONLY)

If you are a Website visitor from the European Economic Area, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only where we need the Personal Data to perform a contract with you, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Data from you.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details below.

10. HOW TO CONTACT US REGARDING YOUR PRIVACY

If you have any questions about this Privacy Notice or seek resolution to any privacy or data collection issue with Orchestra Group, please contact us at iot.support@orchestra.group.

11. UPDATES TO THIS PRIVACY NOTICE

We may modify or update this Privacy Notice at any time to reflect any changes in our privacy practices. Where the changes are material, we will inform you on our Website homepage and we will also indicate at the top of this Privacy Notice the date it was most recently updated. We encourage you to check this Privacy Notice often so that you are aware of how we are protecting your Personal Data.