Last Updated: February 2019

This privacy policy (“Privacy Policy”) governs how we, White Source Ltd. (“White Source” “we”, “our” or “us”) use, collect and store information pertaining to you (“User”, “you”) in the following use cases:

1. When you make general use of our website, whitesourcesoftware.com (“Website”);
2. When you log in to our Platform;
3. When you commence direct communications with us, for example through our help desk chat or Contact Us tab on the Website;
4. When you submit your contact information for requesting a free trial on our Website;
5. When you submit your resume for one of the positions offered on our Website;
6. When we acquire your Personal Data from third-party sources (such as lead-generation companies).

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.

Table of contents:

• What Personal Data we Collect, Why we Collect it, and How it is Used
• How we Protect and Store your Personal Data
• How we share your Personal Data
• Information About You that we Get from Third-Parties
• Additional Information Regarding Transfers of Personal Data
• Your Rights
• US Privacy Provisions
• Use by Children
• 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. 1. 1. WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

         Subject Group	Data We Collect	Why is the data collected and for what purposes?	Legal basis	Third Parties with whom we Share your Data	Period of Storage	Consequences of not providing the data
         User Log in	Name, Email, Profile Picture URL (optional)	So we can identify you as a User; In order to provide you with our services	Necessary for us to provide you with our services	Not Applicable	As long as you use the Services.	You will not be able to access our platform or use our Services
         Free Trial	Name, Work Email, Phone Number, Country, Company (optional)	So we can register you for a free trial in order to user the Services.	At a User’s request, prior to entering into a contract with us	Marketo SalesForce	For as long as reasonably necessary to respond to your enquiry related to the platform demo.	You will not be able to try out our platform.
         Commencing direct communications with us	Name, Work Email, Phone Number, Country, Company (optional), Free Text (optional)	So we can adequately respond to your enquiry, and for further follow-up (if needed)	At a User’s request, either necessary to provide our services to you, or prior to entering into a contract with us	Marketo SalesForce	For as long as reasonably necessary to respond to your enquiry.	We will not be able to respond to your enquiry.
         Log data	Name, Work Email, Company, User IP Address, Timestamp	All log items are recorded for diagnostics and support purposes only.	Necessary for us to provide you with our services	Not Applicable	The WhiteSource data retention policy for data logs is 90 days.	You will not be able to use the Application.
         Navigation data	Cookies	To maintain page history.	Consent	Not Applicable	If you choose to opt out, as soon as reasonably practicable, and within a maximum of 30 days.	Browsing experience may not be optimal.
         When you choose to upload your resume or send your resume to us.	Name, Email Address, Phone Number, Resume, LinkedIn Profile URL (optional), Personal website (optional), Personal note (optional), Cover Letter (optional), Portfolio (optional)	So we can process your resume or LinkedIn profile, and can get in touch with you, regarding job offers that we find you suitable.	At a User’s request, prior to entering into a contract with us	Comeet
         Marketing and lead targeting	Name, Work Email, Company (optional), Country.	In order to target you with relevant marketing campaigns by email.	Consent	Appcues Marketo SalesForce	If you choose to opt out, as soon as reasonably practicable, and within a maximum of 30 days.	We will not be able to improve our Website, or provide you with content and offers which may be of interest to you.

1. 1. 1. HOW WE PROTECT AND STORE YOUR PERSONAL DATA
         1. 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. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. 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.
         2. 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

1. 1. 1. HOW WE SHARE YOUR PERSONAL DATA 
         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, 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).

1. 1. 1. INFORMATION ABOUT YOU THAT WE GET FROM THIRD-PARTIES 
         1. If you access our Services through connected third party applications (such as Google or GitHub), we will receive certain information (including Personal Data, as described in Section 1) about you from the provider of such third party applications. The scope of information we receive depends on your third party application privacy settings.
         2. If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s terms of service and privacy policy.
         3. If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

1. 1. 1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATAWhere we transfer your Personal Data outside of WhiteSource, 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; orWhere we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed; and 
      2. YOUR RIGHTS  The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR. Some of these rights may also apply under your applicable law:
         • 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 dpo@whitesourcesoftware.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 fulfill 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.

1. 1. 1. US PRIVACY PROVISIONS 
         1. California Civil Code Section 1798.83 (and other, similar state statutes) permits our customers who are California residents (or residents of states with similar statutes) to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to dpo@whitesourcesoftware.com. Please note that we are only required to respond to one request per customer each year.
         2. 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 Data you have publicly posted. If you wish to remove such content or Personal Data and you specify which content or Personal Data you wish to be removed, we will do so in accordance with applicable law.  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 Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

1. 1. 1. USE BY CHILDREN We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without the involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

1. 1. 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 dpo@whitesourcesoftware.com.