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Darrow.AI – Privacy Policy

Last Updated: April 30, 2024

INTRODUCTION

Darrow AI, Inc., its subsidiaries, and affiliates, including Darrow.AI Ltd. (together – “Darrow” or “Company“) develops an AI-powered justice Intelligence platform and operates the website www.darrow.ai, its subdomains and its related services and features (“Website”, collectively – the “Services”).

We are dedicated to protecting your privacy rights and making our practices regarding the processing of your personal data more transparent and fair. This Privacy Policy (“Policy”) was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit, install, or interact with our Services. Please note that parts of this Policy may not be applicable to you, depending on the jurisdiction in which you reside and the applicable laws.

Scope: This Privacy Policy applies only to the information we collect in connection with your use of the Website, including when you register to receive more information about our Services and when you submit your candidate information for career opportunities at Darrow.

This Privacy Policy supplements and shall be read in conjunction with our Website Terms of Use (the “Terms”) and our Cookie Policy (the “Cookie Policy”), and may be supplemented by additional privacy statements, terms or notices provided to you.

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time, pursuant to this Policy and our Terms. You are not legally required to provide us with any personal data, but without it we will not be able to provide you with the best experience of using our Services.

01. WHAT TYPES OF DATA WE COLLECT?

We collect personal data from you, meaning any information which potentially allows, alone or together with other data, the identification of an individual with reasonable means (for example, email address or name, collectively “Personal Data“). This section sets out how and when we collect and process Personal Data about you.

1.1 Information received directly from you:

We collect information which you provide us voluntarily. For example, when you request to receive communications from us or when you otherwise contact us directly via the Website:

  • User Data: If you choose to receive a Service that requires to log-in to your account via the Website, we may collect your personal data in respect of your engagement with the respective Service, such as your user account credentials, your business needs and preferences.  
  • Communication Information:

When you send us an email, or contact us via the support or the PlaintiffLink page, or submit any other contact form  within our Services, we collect the Personal Data you provide us. This includes your name, email address and any other information you choose to provide.

  • Personal details that you provide us in connection with your request to receive our communication and updates;
  • Candidates Information: 

     When you apply for employment opportunities at Darrow within our Services, we collect the Personal Data you provide us. 

    • We work with data processors to whom we have instructed to collect, store and process Personal Data on our behalf for the purposes of providing our services, for example, Comeet, as a recruiting and applicant tracking platform (“Platform”) in order to handle your Personal Data as a candidate.
    • Personal Data processed: This may include your full name, phone number, email address, address, CV or resume and at your option (including information such as skills, work experience, education), links to your LinkedIn profile and details of your occupational preferences, information about your candidacy and employment options (such as salary expectation), the source who submitted your candidacy (e.g., recruiting agency, headhunters, referral),  your interviews including call and video recordings, evaluations of your candidacy, internal discussions within the recruiting agency, our responses to questionnaires and other information or materials you or other parties (such as references, evaluators or background check providers) submitted in relation to your candidacy.
    • We may also collect, store and use the following types of sensitive Personal Data (the purposes for which we process this are set out at paragraph 3.2 below):
    • Background check information, credit, drug/alcohol and/or other checks, only where permitted by law, and information received during these checks;
    • Providing some of the personal data listed above is voluntary (e.g., information about your ethnicity, health conditions, religious beliefs, and sexual orientation). In relation to other information that is important for our consideration of your application (such as evidence of qualifications or work history), we will not be able to process your application successfully if you do not provide that information.
    • We will retain your Personal Data for as long as we need it to assess you as a candidate or as long as we have a valid legal basis. In some instances, we may retain your information to consider you for future opportunities at the Company which may be of interest to you. If you do not want us to retain your information, please contact us at legal@darrow.ai.  

1.2 Information we collect when you are using the Website: 

When you visit or access our Websites we may automatically receive and record information through the use (and authorize 3rd parties to use) of  pixels, cookies and other tracking technologies. 

Usage and Technical Information: 

. Such information includes technical information about your interaction with our Services, geolocation data, IP address, unique identifiers (e.g. MAC address and UUID), your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website, methods used to browse away from the Website, as well as other information which relates to your activity in the Services. 

The information collected (including your IP address) may be disclosed to or collected directly by our third-party web analytics service providers such as Google Analytics, as further detailed under the “Tracking Technologies” section below.

1.3 Aggregated data: We may also collect aggregated or technical data generated when you use our Services, relating to how you use them, so we could learn how users and customers use our Services and improve them and our users’experience. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity.

Sensitive Personal Data: We do not intentionally collect sensitive Personal Data (for example, information revealing race, ethnic origin, political opinions, religion, etc.) and we ask you not to provide us with such information.

02. TRACKING TECHNOLOGIES

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies“). 

Cookies: a cookie is a small data file that is downloaded and stored on your computer or mobile device when you visit our Website. 

We use “First Party Tracking Technologies” and also “Third Party Tracking Technologies” that are stored by other third parties. Third-party cookies are aimed at collecting certain information (including Personal Data you provided us via the Website) to deliver our targeted advertisements based on user’s online activity and interests.  

These Tracking Technologies allow us to automatically collect information about you, your device, and your online behaviour, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics, customize your experience and offer you, for example, tailored content and personalized advertisements that better correspond with your interests. 

For example, these technologies enable us to: (i) keep track of our users’ preferences and authenticated sessions, (ii) secure our Website by detecting abnormal behaviours, (iii) identify technical issues and improve the overall performance of our Website, and (iv) create and monitor analytics. 

You can learn more about our use of these technologies by reading our Cookie Policy.

You can delete cookies in your browser. If you turn cookies off, some of the features that make the Website’s experience more efficient may not function properly.

Below is a list of useful links that can provide you with more information on how to manage your cookies:

  1. Google Chrome;
  2. Mozilla Firefox;
  3. Safari (Desktop);
  4. Safari (Mobile);
  5. Android Browser; and
  6. Microsoft Edge

You can turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

  1. The Interactive Advertising Bureau (US);
  2. The Interactive Advertising Bureau (EU); and
  3. European Interactive Digital Advertising Alliance (EU) .

You can learn more about our use of Tracking Technologies by reading our Cookie Policy.

03. WHY WE PROCESS YOUR PERSONAL DATA?

This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.

Purpose Legal basis under GDPR (if applicable)
Provision and operation of our Services; Support. We use your Personal Data, such as your name and email address, to provide you with our Services and provide customer support. This includes, for example, allowing you to log-in or responding to your inquiries. The legal bases for processing this data are the performance of our contractual  obligations towards you; your consent (for example, when you provide Personal Data); and our legitimate interests. Our legitimate interests in this case are provision of our Services and supporting our customers.
Improve our Services. We collect and analyse Personal Data about you and your usage of our Services for the purposes of usability, quality, functionality and effectiveness of our Services and their user experience. The legal basis for processing this data is our legitimate interest. Our legitimate interests in this case are providing and improving, developing and maintainig our Services.
Anonymize or de-identify your Personal Data, create cumulative data that is non-personal, which we might make use in order to operate and improve our Services, and for research purposes. The legal basis for processing this data is your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing and improving our Services.
Communicate with you, notably when you contact us or submit a request to us. The legal bases for processing this data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with the requested services.
Marketing and Advertising. We use your Personal Data in order to provide you with advertisements, updates, notices, notifications, newsletters and additional information when you visit our Services, including personalized and non-personalized advertising. The legal bases for processing this data are your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests. 
Optional Recruitment. We process your Personal Data as part of our  receipt of applications for employment opportunities at Darrow.  The legal basis for processing this data are your consent (when required). Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; Our legitimate interest in this case is recruitment management.
Integrity. We process certain information about you and your usage of our Services in order to keep the integrity and security of our Services, identify your identity and enforce our policies. The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services; detection of fraudulent activities; and the safety of our end-users.
Compliance with applicable laws; assistance to law enforcement agencies; response or defend against legal proceedings. We process your personal data in order to comply with our legal obligation under applicable laws. The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are compliance with our legal obligations and assisting law enforcement agencies.
Protect and enforce our rights, privacy and security, prevent fraud  or other illegal activity, safety of our systems, users and property, or those of other persons or entities, conduct audits, defend legal claims and resolve disputes. The legal basis for processing this data is your consent (when required) and our legitimate interests. Our legitimate interests in this case are protecting our Services.
04. WITH WHOM WE SHARE YOUR DATA?

4.1 We disclose your Personal Data as described below:

  • Service providers: 

Our service providers that serve in facilitating and enhancing our Services, work on our behalf and may need access to certain Personal Data in order to provide their services to us. These companies include, but are not limited to, hosting services, analytics services, Website functionality and operation services, marketing services, identity verification providers, recruiting and applicant tracking platform for handling recruitment processes including but not limited to, Comeet (who provide us with the candidacy platform) etc. These service providers are authorized to use your Personal Data as necessary to provide these services or as otherwise authorized by us. Third party advertisers: 

We partner with third parties to either display or to manage our advertising on other websites or apps. Our third-party advertisers use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you advertising based upon your browsing activities and interests

  • Compliance with laws and assistance to law enforcement agencies: 

We may disclose your Personal Data to government or law enforcement officials or private parties. The disclosure will be made in our sole discretion, as we believe it necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. 

  • Auditors and advisers: 

We may share your Personal Data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards, auditing, managing disputed etc.

  • Protecting our rights and safety:

We may share your Personal Data to enforce this Privacy Policy or the Terms of Use, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; or otherwise if we believe in good faith that this will help protect the rights, property or personal safety of any of our users, or any member of the general public.

  • Affiliated companies, mergers and acquisitions: 

We may share your Personal Data with our affiliated companies. In addition, we may transfer or share your Personal Data in case of entering into a business transaction (including during negotiations) such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets, with the parties involved in such event. Such disclosure shall be subject to the terms of this Privacy Policy. 

For avoidance of doubt, we may share anonymized or de-identified information with any other third party, at our sole discretion.

05. MARKETING AND ADVERTISING

We use your Personal Data ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, ads, products, services, websites and applications which relate to our affiliated companies or our business partners (collectively: “Marketing Affiliates”), which we believe may interest you.

You can decline receiving further marketing offers from us or from our business partners and Marketing Affiliates at any time, by contacting us at info@darrow.ai. Please note that even if you unsubscribe from our marketing-mailing list, we can continue to send you service-related updates and notifications.

06. YOUR RIGHTS

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights (some of which only apply to individuals protected by the GDPR, and may be subject to certain exemptions or derogations):

6.1 Rights of access to your Personal Data:

You may have the right receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.

6.2 Right of data portability:

 

You may have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability;

6.3 Right of rectification:

You may have the right to request rectification of your Personal Data in our control in the event that your believe the Personal Data held by the Company is inaccurate, incomplete or outdated;

6.4 Right of deletion/erasure:

You may have the right to request that the Company erase or delete Personal Data held about you at any time;

6.5 Right to restriction or objection to processing:

You may have the right to request that the Company restrict or cease to conduct certain Personal Data processes at any time;

6.6. Right to withdraw your consent: 

To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time;

6.7. Right to limit use and disclosure of your sensitive Personal Data: 

You may have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services;

6.8. Right not to be subject to automated decision making:

You may have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.

07. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section addresses the specific disclosure requirements under California privacy laws, including the California Consumer Privacy Act of 2018 and the California Consumer Privacy Act Regulations (collectively, “CCPA”). 

7.1 Categories of Personal Information we collect

In the preceding 12 months, we may have collected the following categories of Personal Data (as defined in the CCPA):

  • Contact information provided by our users.
  • Contents of users’ interaction with our customer support.
  • Technical Identifies, such as IP address and cookie history.
  • Activity on our Website, such as clickstream and engagement with our Website properties.
  • Users’ browsing journey from and to our Website.
  • Inferences, which are drawn from the above information to enhance the Services and customize content and functionality.
  • Characteristics of job applicants, pursuant to Section 1.1 above.

7.2 Sources of Personal Data

The sources from which we obtain Personal Data are:

  1. Directly from our users (either actively, when you contact us via the Website, apply for a job application, or through monitoring of use of the Website by cookies and other tracking technologies);
  2. Social networks, such as LinkedIn with whom candidates hold an account;
  3. Third Parties such as our advertising partners, data analytics providers, recruiters and employment agencies.

7.3 Sharing or selling Personal Data

We do not act as data brokers or otherwise trade in your data.  However, under some US data protection laws, like the CCPA, our disclosure of certain internet activity and device information with third parties through cookies on our Website may be considered a “sale” or “sharing” of Personal Data. We do so in pursuit of the business and commercial purposes described above. 

The purpose for collecting, sharing or selling information: administering the provision of our Website and Services, authenticating users access requests when they log-in or access our properties, providing customer support as required, detecting and preventing security incidents, debugging and fixing errors, maintaining and enhancing our Website and Services, allowing users to receive our commercial communications when they have agreed to receive them, marketing our services and attributing engagement with our Website and Services to the applicable marketing campaigns.

For the purpose of the CCPA, in the last 12 months we may have ‘sold’ or ‘shared’ your Personal Data mentioned above with other parties as necessary for the purposes described above, for example:

  1. Data analytics, advertising and marketing vendors
  2. Service providers. such as hosting services, Website functionality and operation services, recruiting services (including but not limited to, Comeet who provides us with the candidacy platform), recruiters, marketing services.  
  3. Third party parties that collect information on our users through our Services for serving ads and marketing materials and related activities such as campaign measurement and analytics
  4. Affiliates. Our corporate parent, subsidiaries, and other affiliates under the control of our corporate parent, for purposes consistent with this Policy or to operate shared infrastructure, systems and technology.
  5. Law enforcement, government bodies, regulators and other parties for legal reasons. We may share your personal data with third parties as required by law or if reasonably necessary to (i) detect and investigate illegal activities and breaches of agreements; and/or (ii) exercise or protect the rights, property, or safety of the Company, our personnel or others.
  6. Business transfers. Parties to transactions and potential transactions whereby we sell, transfer or otherwise share some or all of our business or assets, including your Personal Data, such as a merger, consolidation, acquisition, reorganization or sale of assets (including negotiations for such transaction), or in the event of bankruptcy or dissolution.
  7. Professional advisors. Lawyers, immigration advisors, and other outside professional advisors.

California Privacy Rights: 

RIGHT TO ACCESS

If applicable, California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may make this request up to two times in a 12-month period.

RIGHT TO REQUEST ADDITIONAL INFORMATION

If applicable, you may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell your personal information and the categories of personal information we have disclosed, shared and sold about you in the preceding 12 months. This information is provided in Section 7 (Additional Information for California Residents).

RIGHT TO DELETE

If applicable, you also have the right to request deletion of your personal information, subject to certain applicable legal exceptions.

RIGHT TO OPT OUT OF SALE OF PERSONAL INFORMATION

If applicable, you have the right to opt-out of sales of personal information and to receive equal service and price and not be discriminated against even if you exercise any of your CCPA rights (unless permitted by applicable law, such as if the differences are reasonably related to your information). Our Privacy Policy describes the limited circumstances in which we may share your information with third parties.

HOW TO MAKE A CCPA REQUESTS?

To make an access request, a deletion request or an “opt-out” of the “sale” request (as described above), please email info@darrow.ai. Before completing your request, we may need to verify your identity or the identity of your authorized representative. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity. You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA.

7.4 Right to lodge a complaint and appeal our decisions:

all requests, complaints or queries may be addressed to the Company to the following email address: info@darrow.ai. 

We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Please note that these rights are not absolute, and may be subject to the relevant applicable laws, our own legitimate interests and regulatory requirements.

Authorized agent

  • You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:
    1. The authorized agent is a natural person or a business entity; and
    2. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
  • The request must:
    1. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you; and
    2. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
  • We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

08. TRANSFER OF PERSONAL DATA

We operate globally, thus any information that we collect, disclose or share, including your Personal Data, can be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area, the United States, Israel,  for the purposes detailed in this Policy.

However, to the extent that the GDPR is applicable, we will only transfer or share your Personal Data to data recipients

  1. located in the EEA;
  2. located in non-EEA countries which have been approved as providing adequate level of data protection; or
  3. who entered into legal agreements ensuring an adequate level of data protection.
09. HOW WE PROTECT YOUR PERSONAL DATA?

We have implemented administrative, technical, and physical safeguards to reduce the risk of  unauthorized access, use, or disclosure of your Personal Data. Your information is stored on secure servers and is not publicly available. 

We limit access of your Personal Data only to those employees, third party service providers or partners on a “need to know” basis, and strictly in order to enable us to perform the agreement between you and us.

Despite these measures, Darrow cannot provide absolute information security or eliminate all risks associated with Personal Data, and security breaches may happen. If there are any questions about security, please contact us at info@darrow.ai.

10. MINORS

We do not knowingly sell or share personal information of users under the age of 18.

We do not knowingly collect or solicit Personal Data from Minors (as determined under the applicable laws where the individual resides; “Minors”). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. If you believe that we might have any information from or about a Minor without verification of parental consent, then please contact us through the contact details available below.

11. RETENTION

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

12. UPDATES TO THIS POLICY

We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. In the event of material changes, we will provide a notice via the Services or by other means. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

13. CONTROLLING VERSION

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

14. GOVERNING LAW

This Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its conflict of law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

15. CONTACT US

If you have any further questions, please contact us by email at: contact@darrow.ai.

Address: Yitzhak Sadeh St. 8, 21st Floor. Tel Aviv-Yafo, Israel.