4. Information collected automatically.

I. Pillar may automatically collect data when User visits, interacts with, or uses the Site, including but not limited to:

II. Identifiers and information contained in cookies;  

III. User's settings preferences, backup information;

IV. Content User viewed or searched for, page response times, and page interaction information(such as scrolling, clicks, and mouse-overs);

V. Network and connection information, such as the Internet protocol (IP) address and information about User's Internet service provider;  

VI. Device information, such as browser type and version, operating system, or time zone setting; location of the device, encounters with other devices using the Site.

1. Pillar may process User's personal data to operate, provide, and improve the Site, including but
not limited to:

I. contacting User and communicating with User with respect to the Site and/or Pillar's services;

II. identifying User's interests and recommending offers that might be of interest to User;

III. marketing and promoting Pillar's services;

IV. providing assistance, notification and support;

V. fulfilling User requests; meeting contractual or legal obligations;  

VI. protecting Users security, e.g. preventing and detecting fraud;

VII. internal purposes, e.g. trouble shooting, data analysis, testing and statistical purposes.  

1. Pillar may use tracking mechanisms such as cookies on the Site so that Pillar may:  

I. facilitate and customize the User'sexperience of the Site,

II. track User's use of the Site,

1. Pillar may be required to retain or disclose personal data in to the following cases:

I. Provide User’s with the Services;

II. Where User provide his consent;

III. comply with applicable laws or regulations;

IV. comply with a court order, subpoena or other legal process;

V. respond to a lawful request by a government authority, law enforcement agency or similar government body (whether situated in User's jurisdiction or elsewhere);  

VI. engage withthird-party service providers and/or sub-contractors which provide services for Pillar's business operations, a list of which can be received upon request;

VII.  disclose and/or transfer data to another entity if Pillar is acquired by or merged with another entity, if Pillar sells or transfer a business unit or assets to another entity, as part of a bankruptcy proceeding, or as part of any other similar business transfer;

VIII. Pillar believes release is appropriate to comply with the law, enforce or apply Pillar's terms and other agreements, or protect the rights, property, or security of Pillar, Users, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.

1. Definition

“Personal Data” means data that may be used, either alone or together with other information, to identify an individual user, including, without limitation, a user’s name, address, telephone number, username, email address, city and country, geolocation, unique identifiers, picture, or other similar information and includes personal data as defined in the General Data Protection Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR").  

2. Legal Basis for Processing of Personal Data

Pillar will only process User's Personal Data if it has one or more of the following legal bases for doing so:

I. Contractual Necessity: processing of Personal Data is necessary to enter into a contract with User, to perform Pillar's contractual obligations to User under the TOU, to respond to requests from User, or to provide User with customer support;

II. Legitimate Interest: Pillar has a legitimate interest to process User'sPersonal Data;

III.  Legal Obligation: processing of User's Personal Data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or IV. Consent: processing of User's Personal Data with User's consent.

3. User's Rights regarding Personal Data

I.  Subject to applicable law, User has certain rights with respect to User's Personal Data, including the following:

a. User may ask whether Pillar holds Personal Data about User and request copies of such Personal Data  and information about how it is processed;

b. User may request that inaccurate Personal Data is corrected;

c. User may request the deletion of certain Personal Data;

d. User may request Pillar to cease or restrict the processing of Personal Data where the processing is inappropriate;

e. When User consents to processing User's Personal Data for a specified purpose by Pillar, User may withdraw User's consent at any time, and Pillar will stop any further processing of User's data for that purpose.

II. In certain circumstances, Pillar may not be able to fully comply with User's request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Pillar will still respond to notify User of such a decision.  

III. User can exercise User's rights of access, rectification, erasure, restriction, objection, and data portability by contacting Pillar at privacy@pillar.security. In some cases, Pillar may need User to provide Pillar with additional information, which may include Personal Data, if necessary to verify User's identity and the nature of User's request.

4. Transfer of User's Personal Data outside of the EEA

I.  The data that Pillar processes in relation to Users may be transferred to, and stored at a destination outside the European Economic Area (“EEA“), e.g. Israel and the USA, that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who works for us or for one of our service providers:

a. In order to store it.

b. Where we are legally required to do so.

c. In order to facilitate the operation of our businesses, where it is in our legitimate interests and we have concluded these are not overridden by User's rights.

II. Where Personal Data is transferred by Pillar or Pillar's affiliates in relation to providing the services Pillar will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, which may include by entering into European Commission approved standard contractual clauses relevant to transfers of Personal Data and that it is treated securely and in accordance with this Privacy Policy. 

Each User is advised to be aware that personal data Pillar collects may be transferred to, processed and stored outside User's jurisdiction, and that data protection laws in the jurisdiction where the information is collected stored and/or processed may differ from User's jurisdiction including in Israel, the EU, the UK, and the US, as reasonably necessary for the proper performance and delivery of the Pillar services, or as may be required by law.

Each User hereby gives User's consent to this transfer, processing and storage of User's information outside its jurisdiction.  

Pillar will retain users Personal Data for a period of time consistent with the original purpose of collection (see Section C, “Pillar's Use of Personal Data”). Pillar determines the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of Users’ Personal Data processed, the potential risk of harm from unauthorized use or disclosure of Users’ Personal Data, and whether Pillar can achieve the purposes of the processing through other means, as well as on the basis of Applicable Data Protection Law requirements (such as applicable minimum statutory retention requirements). After the expiration of the applicable retention periods, Pillar will delete Pillar Personal Data. If there is any data that Pillar are unable, for technical reasons, to delete entirely from Pillar’s systems, Pillar will put in place appropriate measures to prevent any further use of such Personal Data.

To the extent the California Consumer Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq. ("CCPA"), including any subordinate or implementing legislation, is applicable the following shall apply:

1. Pillar will only process personal information on User's behalf.

2. Pillar will (i)not collect, retain, use, or disclose personal information for any purpose other than for the specific purposes set out in the Pillar Privacy Policy, and the Data Processing Agreement between Company and User; (ii) not sell Personal Data (as defined under the CCPA); and (iii) put in place appropriate technical and organizational measures to protect personal information against unauthorized or unlawful processing or accidental destruction, loss or damage.

Pillar does not knowingly collect or solicit any information from anyone under the age of 18. The Site is not directed at children under the age of 18. In the event that Pillar learns that it has collected personal data from a child under the age of 18 without consent from a parent or a guardian, Pillar will delete that personal data as quickly as possible. If User believes that Pillar might have any information from or about a child under 18, User should contact Pillar at: privacy@pillar.security

If User has any questions about this Privacy Policy or Pillar's privacy and/or data protection practices in general, please contact us using the following information:

Email: privacy@pillar.security