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Privacy Policy

Last Updated: February 21, 2020

1. Introduction

Getapy Ltd. values the trust our users and customers place in us when they give us access to their personal data. The Privacy Policy describes how we work to maintain that trust and protect that information.

In particular, this Privacy Policy details our collection, use and disclosure of personal and non-personal data you give to Getapy Ltd. when you access or use Getapy Ltd.’s online and/or mobile services and websites, and software provided by Getapy Ltd. on or in connection with such services or websites (collectively, the “Site”).

1.1 The Getapy Ltd. Entities Responsible for Your Information

All references to Mentors and Mentees are defined as provided for in the Getapy Ltd. Terms of Service Introduction.

With respect to Mentees, for the purposes of this Privacy Policy, “Getapy Ltd.” or “we” means Getapy Ltd. if you are a Mentee located in Canada, or a Mentee located outside of Canada.

With respect to Mentors, “Getapy Ltd.” or “we” means Getapy Ltd. if you are a Mentor located in Canada, Getapy Ltd. or a Mentor located outside of Canada.

Getapy Ltd. is the controller for the Personal Data we process, unless otherwise stated in these terms or provided for in a separate agreement.

1.2 Personal Data and Non-Personal Data

Personal data (“Personal Data”) refers to any information that relates to an identified or identifiable individual, and non-personal data (“Non-Personal Data”) refers to any information that does not identify you as a specific individual. Please note that at all times Getapy Ltd. will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.

1.3 The Scope of Getapy Ltd.’s Privacy Policy

This Privacy Policy covers only data that we collect through the Site, and not any other data collection or processing, including, without limitation, the data collection practices of any affiliate or other third party, including any third-party operators of web pages to which the Site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy.

Occasionally, we may refer to this Privacy Policy in notices on the Site, including special purpose web pages, mobile applications, or other resources, for example, if we invite you to submit ideas to improve the Site. This Privacy Policy applies to information collected by us through such special purpose resources, as modified in the particular notice (e.g., with respect to the types of data collected or our uses or disclosures of such information). Getapy Ltd. may amend this Privacy Policy at any time.

1.4 Changes to the Privacy Policy

Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Policy. If Getapy Ltd. is going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then Getapy Ltd. will notify users via email and/or by posting a notice on Getapy Ltd.’s Site for 30 days prior to such use or by other means as required by law.

1.5 Getapy Ltd.’s approach to privacy and the General Data Protection Regulation (GDPR)

Please note this Privacy Policy describes, in a comprehensive manner, how Getapy Ltd. processes your data. For more information on Getapy Ltd.’s approach to privacy and GDPR, click here.

2. Information Collected

You provide different types of information in order for Getapy Ltd. to provide our services, products and features to you. Getapy Ltd. associates this information with your Getapy Ltd. profile.

2.1 Information You Provide to Getapy Ltd.

– From Your Account

We collect data from you when you create a Getapy Ltd. account, request information, subscribe for a service, participate in a survey, post a rating or review, post a question or answer, post minutes in the online tool, discuss with a Getapy Ltd. representative, upload content or otherwise actively send us data on our Site. This may include, but is not limited to, your user name, password, first and last name, email address, telephone number (including mobile phone number), street address, gender, occupation, interests, messages you send to users, and any other data included in a submitted profile, including but not limited to mentor / mentee materials and messages shared between mentors / mentees through Getapy Ltd. and answers you give to any form sent to you. This information may be associated with your profile.

– Through Your Activity on Getapy Ltd.

In addition, as part of the standard operation of the Site, Getapy Ltd. may collect and analyze information from your computer or mobile device and actions taken on the Site, including, but not limited to, your resume, social profiles, your searches on Getapy Ltd., your searches, click on or book to, where those mentors are located, Skills and challenges interest or industries, the price range or experience level of the mentor you view (where indicated), your activity time on the Site and each page, page views, clicks, taps, session activity, browser type, operating system, type of device, MAC address, IP address and the domain name from which you accessed the Site. When you submit a photo to the site, this may include the provision of the location data of where the photo was taken. Getapy Ltd. seeks your consent at the time of such provision, and such processing will only be performed where consent is secured. 

– When Using Automated Phone Screening

If you use any automated phone screening product, Getapy Ltd. will record and store your answers to a Mentor screening questions and will forward your answers to the Mentor. Where you wish to use such a product, you will agree in advance to Getapy Ltd. listening to and analyzing the recording in accordance with this Privacy Policy.

– When Providing Mentor Information

As a user, Getapy Ltd. may request that you provide certain Personal Data to Getapy Ltd. in order to verify your account. This information may include, but may not be limited to, your Social media account link, resume, Business Registration information, or a utility bill, Bank account information, sales tax number, the name and email address of a company representative if constituted as a moral entity or your personal information (name, email, phone and address).

This information will be used for internal purposes only, subject to any request by law enforcement or a court order. In connection with chargeable services, we will also collect payment information (e.g., the last four digits of credit card numbers and related verification information, bank account number and address). Please note that Getapy Ltd. only has access to the last four digits of Mentee credit card numbers, and does not store full credit card numbers.

2.2 Information Collected When You book a mentor or Access Getapy Ltd. from Some Third-Party Websites

– When You book a mentor on Some Third-Party Sites

Getapy Ltd. may also collect information about web sites and web pages you visit through our mobile software or while using Getapy Ltd. for Chrome about mentors profile that you save, notes or applications statuses that you save or update, or data regarding how you engage with websites or other actions you take on such website, including URLs of websites you visit. We do this in order to allow a Mentee to keep a record of particular Job Listings of interest, to detect a mentors profile booking form on a third-party website to give a Mentee the option to auto-fill parts of the form using Getapy Ltd. Mentee profile, or to confirm a booking. Getapy Ltd. for Chrome also allows Getapy Ltd. to learn about what types of profile and Getapy Ltd. product features are of interest to you, so that we can provide you with improved profile listing searches, profile listing recommendations and product features. 

– When You Log In or Use Getapy Ltd. from Some Third-Party Sites

You may also create an account or log in to your Getapy Ltd. account using third-party websites including, but not limited to, Linkedin, Facebook or Google. If you do not already have a Getapy Ltd. account but log in to Getapy Ltd. using your Linkedin, Facebook or Google account, this creates a Getapy Ltd. account using the same email address used in your Linkedin, Facebook or Google account. If you agree to provide this information to Getapy Ltd., Linkedin, Facebook or Google will authenticate you and redirect you to Getapy Ltd.’s Site. Please note, when you log in to Getapy Ltd. using your Linkedin, Facebook or Google account, Linkedin, Facebook or Google will cookie you in order to authenticate you as a Linkedin, Facebook or Google user.

By accessing Getapy Ltd. through your Linkedin, Facebook or Google account, you understand that Linkedin, Facebook or Google will share certain data detailed in the above paragraph for the purposes of authentication to permit you to access our Site in a secure manner. You may stop this at any point from your Linkedin, Facebook or Google account. This information will be considered Getapy Ltd. account information for purposes of your use of the Site.

You have the ability to disable the connection between your Linkedin, Facebook or Google account and your Getapy Ltd. account at any time by accessing your privacy settings on your Linkedin, Facebook or Google account. Linkedin, Facebook and Google may also ask for your permission to share certain other details with Getapy Ltd., including but not limited to your name, profile picture, public profile information, and email address. Once you give this permission, the requested information will be shared with Getapy Ltd., which may use this information to provide Services to you, including populating your Getapy Ltd. profile. The shared information will remain associated with your Getapy Ltd. profile until you modify or delete it. For those users that avail of Getapy Ltd. Family specifically, Facebook may ask for permission to share your friends list, and Getapy Ltd. may use some of this data to connect you with other users of Getapy Ltd. Family.

PLEASE NOTE THAT YOUR RELATIONSHIP WITH LINKEDIN, FACEBOOK OR GOOGLE OR ANY OTHER THIRD-PARTY WEBSITE IS GOVERNED SOLELY BY YOUR AGREEMENT WITH SUCH THIRD-PARTY WEBSITE.

2.3 Any Other Personal Data Getapy Ltd. May Receive from Third Parties

Any Personal Data that Getapy Ltd. may obtain from other third-party sources will be processed by Getapy Ltd. in accordance with this Privacy Policy and all applicable laws.

2.4 Storage of Your Information

Getapy Ltd. shall retain users’ Personal Data to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. In particular, Getapy Ltd. shall not retain Personal Data for any longer than necessary for the purposes of performing the processing outlined in this Privacy Policy.

If you create a Getapy Ltd. account, your information may be collected and stored in a manner that connects to your account email address. Getapy Ltd. may also create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, email address, or zip code. For example, while using a mobile device to access Getapy Ltd., Getapy Ltd. may provide users with relevant profile informations that are located within the same zip code as where this activity is taking place. The collection of this data is solely used in accordance with the purposes outlined in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable.

Getapy Ltd. may also store the information detailed in this section 2 of the Privacy Policy on its equipment or the equipment of third parties that Getapy Ltd. has a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules.

2.5 What Personal Data is Required

Getapy Ltd. will indicate to you at the point of provision as to whether or not particular Personal Data provided by you is required in order to provide particular Getapy Ltd. services or features to you. Where Personal Data that is required is not provided by you then the particular feature or service may not be available to you.

2.6 The Legal Basis on Which Getapy Ltd. Collects Your Personal Data

Getapy Ltd. collects and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this here.

– Performance of a Contract

Some of the Personal Data processed by Getapy Ltd. is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement. An example of this would be where Getapy Ltd. connects a Mentee to a Mentor.

– Legitimate Interest

A second ground relied upon by Getapy Ltd. for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by Getapy Ltd.. Such legitimate interests will include where Getapy Ltd. sends you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. Getapy Ltd. will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.

– Compliance with a Legal Obligation

A third ground relied upon for certain types of processing is that it is necessary in order to allow Getapy Ltd. to comply with a legal obligation. An example of this would be where Getapy Ltd. is required to retain business records for fixed periods of time in order to comply with local legal requirements.

– Consent

Finally, in certain limited situations, Getapy Ltd. relies on your consent in order to process your Personal Data. Where Getapy Ltd. requires your consent in order to collect and process certain Personal Data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured. For example, your consent will be sought where you provide your location when you provide it yourself on the Getapy Ltd. Apps to help you find more relevant profiles (including from the location service on your mobile device when you grant permission to a Getapy Ltd. App), when you submit a photo that includes the provision of the location data of where the photo was taken, or in certain instances where you initiate a marketing message such as a newsletter with Getapy Ltd. (detailed in section 4 of this Privacy Policy). You can withdraw your consent, as detailed in section 10 of this Privacy Policy where applicable, or by sending an email to Info @ getapy..com (remove spaces when sending email).

3. Limitation of Use or Disclosure of Personal Data

3.1 Where a user Wants to Close a Mentee Account

When a user (Mentor or Mentee) closes an account, the user will no longer have access to any of the data we make available under that account name, including but not limited to, search history, preferences, saved profiles, profile connections, Newsletter, your profile, your meetings, your meeting minutes and any other data associated with the account. If the user uses the same email address to set up a new account, this data from a previous account will not become available to the user again. Please also note that closing your user account may result in you losing access to all Getapy Ltd. products. Getapy Ltd. reserves the right to keep any materials in a closed account as necessary to preserve and protect its rights to the extent permitted by law (for example, to preserve records of a dispute) or to comply with its obligations under local law (for example, if requested to retain by law enforcement). A closed account does not mean that all of the data is expunged from the Getapy Ltd. systems, although it will not be readily available under the user original account name. When the user presses the cancel account button on the dashboard, Getapy Ltd. will begin to process that instruction within 24 hours and will have completed the operation within 40 days.

If a user wishes to access or delete their Personal Data held by Getapy Ltd., they should follow the steps listed in section 10 of this Privacy Policy, and such a request will be processed in accordance with applicable rules.

3.2 Where a user Wants to Close a Mentor Account

Mentors may close an account at any time by contacting Getapy Ltd. Customer Support. Please note that Getapy Ltd. must preserve business records pertaining to that account to comply with its obligations under law. Alternatively, if a Mentor wishes to access or delete their Personal Data held by Getapy Ltd., they should follow the steps listed in section 10 of this Privacy Policy, and such a request will be processed in accordance with applicable rules.

3.3 Where a Mentee Wants to Delete a connection with a Mentor

If a Mentee wants to delete a connection performed on Getapy Ltd.’s Site, they are advised to access their account and end the relationship, as an extra step contact the platform via the built in chat system directly to confirm deletion. For connection requests which you, the Mentee submit through Getapy Ltd. (including the use of a Getapy Ltd. Book now button) to a Mentor, (with related materials submitted), please note: 1) that your connection request and materials may be controlled by us and the Mentor; 2) we may direct you to that Mentor for Personal Data deletion requests where that Personal Data is held by that Mentor; and 3) Getapy Ltd. depends on the Mentor or the Mentor’s moral entity to provide Getapy Ltd. with the correct destination for all material shared.

3.4 Where the Mentor Contact Details Provided to Getapy Ltd. Are Incorrect

In the event that the contact information (email, telephone number, address, VOIP username) provided to Getapy Ltd. is incorrect, your application materials will not be sent to the intended recipient of the connection. Getapy Ltd. has no liability for such connections. If you do not wish to send your connection or materials in this manner, you should send them directly to the Mentor.

3.5 @Getapy Ltd. mail Addresses

When communicating through Getapy Ltd.’s message relay system, you will see an email address with an @getapyemail.com or @H.O.B. Sync Ltd.mail.com ending. You understand that you retain no ownership rights in these email addresses, which are specific to user communications, but are owned by Getapy Ltd.. However, Getapy Ltd.’s relay system will show the name associated with your account or connection request in the “To:” or “From:” field.

Please also note that since these message proxy and relay services depend on the functionality of third-party providers, there may be technical delays on the part of those email service providers.

3.6 Minimum Age of our Users

The Site is not for use by anyone under the age of 18. However if local laws require that you must be older in order for Getapy Ltd. to lawfully provide the services in the Site to you then that older age shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use Getapy Ltd. under the supervision of your parent, legal guardian or responsible adult. Getapy Ltd. adopts a range of measures to try to ensure that we do not accept individuals who do not meet the minimum age and any other applicable age requirements. If you do not satisfy these age requirements, please email info @ getapy..com (remove spaces when sending email).

4. Purposes, Uses and Disclosures of Information

We may use any information collected pursuant to this Privacy Policy, including Personal Data, for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. Getapy Ltd. associates Personal Data with your Getapy Ltd. profile in order to perform the activities described in this Privacy Policy. Getapy Ltd. uses such information to help Mentees find Mentors profiles and to help Mentors find Mentees. In order to do this we use your Personal Data to:

1) provide our services, products and features to you, to help Mentees find Mentors and Mentors find Mentees;

2) to measure and improve those services, products and features; and

3) to protect our users and provide them with customer support.

More detail on these purposes, uses and disclosures of your information is set out below.

4.1 Creating an Account, Sending You Newsletters or Emails and Other Promotional Materials

If and to the extent permitted by applicable law, Getapy Ltd. may use your contact information to (i) create an account; (ii) send you Newsletters or Emails; and (iii) send you information about Getapy Ltd., including promotional materials. Getapy Ltd. may use third-party partners to perform these activities on Getapy Ltd.’s behalf.

A Newsletter or Email is defined as an email sent to you that you sign up for containing profiles in response to a search query you have run (“Newsletter”). Newsletters may also include profiles that Getapy Ltd. recommends for you, Getapy Ltd. profiles, companies you may be interested in following, or other actions you may want to take on the Site.

Getapy Ltd. may also share your information with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you. Such advertisements will only relate to Getapy Ltd.’s services, products, and features, all of which focus on helping Mentees find Mentors and Mentors find Mentees. If you wish to opt out of receiving any marketing messages from Getapy Ltd. please see section 10.3 of this Privacy Policy.

4.2 Giving You Relevant Search Results and Recommended profiles

In order to optimize our services, products and features for you, Getapy Ltd. may use your previous search and browsing history (e.g. the profiles you click on), or any material and content you add to the site, to identify you and determine relevant search results and provide you with recommended profiles or reach out to you about profiles you may be interested in. We may also use demographic and/or profile data to tailor your experience on the Site, to show you content that Getapy Ltd. thinks you may be interested in, and display content according to your preferences. Getapy Ltd. may return different results for the same search query and has full discretion with respect to the profiles listings it presents in response to any particular search.

4.3 Your Contact Information

When you give Getapy Ltd. contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that Getapy Ltd. may utilize this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that Getapy Ltd. may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your Getapy Ltd. account or through other means such as email, telephone (including mobile phone), chat, or postal mail, including through the use of contact information that you may provide to Getapy Ltd. or that Getapy Ltd. may otherwise obtain from third-party resources.

4.4 Your profile Information

Your information, including Personal Data, gets placed on the Site when you upload or edit content, which becomes part of your Getapy Ltd. profile. Getapy Ltd. reserves the right to charge third parties a fee for accessing your information, including Personal Data, as part of Getapy Ltd.’s services. At your direction, Getapy Ltd. may also send your content to third parties if you choose to connect with another user. Your information is made available to third parties via Getapy Ltd., in accordance with this Privacy Policy. When a Mentee creates a profile on Getapy Ltd., this profile is made public. This is detailed below.

– Public profiles

Public profiles are available to anyone with access to Getapy Ltd.’s profile search application and may be accessed by other Getapy Ltd. users, in order to increase the visibility of that profiles and help Getapy Ltd. find you a connection. Where this occurs, you make your profile, your name and other Personal Data that you place on your profile available to third parties. Those third parties may be interested in you as a connection, and may forward your profile to other third parties.

When you have a public resume, this may be crawled by, and displayed through search engines when someone searches for your name or given attributes of the content of your profile. This means that third parties can view the Personal Data contained in your profile and you may receive unsolicited contact from parties unaffiliated with Getapy Ltd. and for whom Getapy Ltd. has no responsibility. When you post a public resume on Getapy Ltd., please note that although Getapy Ltd. expressly prohibits the scraping of its Site any profile you post publicly is public information and the content may be copied by a third party in violation of these terms.

For public profiles, you also authorize Getapy Ltd. to remove or scramble your name from your public profile, in certain instances. Getapy Ltd. may also change the display of your profile in certain instances to maintain the quality of the profile database.

If you have a public profile, Getapy Ltd. may use information from your profile to auto-fill all or parts of a form. For example, if you use Getapy Ltd. Chat, your name from your profile may appear in the messages.

– Changing Your profiles Privacy Settings

The only option to make your resume private or inaccessible is to cancel your account on Getapy Ltd.. Where you adjust your profile from public to private (hence cancelled account), Getapy Ltd. does not warrant how often third-party search engines will update their caches, which may continue to contain your profile information. Additionally, Mentors who have saved your profile while it was public may continue to have access to your profile even after you have adjusted it to private.

4.5 Matching Mentees With Mentors

You acknowledge that Getapy Ltd. may determine whether the words of your profile or any other individuals’ challenges match the words of certain skills, and vice versa, in order to improve the Site or any other Getapy Ltd. product or service (including by displaying or otherwise making available potentially relevant profiles to Mentees and Mentors).

Getapy Ltd. may also provide information collected pursuant to this Privacy Policy, including Personal Data, to Mentors that may be interested in contacting you. By making connection requests, answering questions, providing your contact information to show interest in a user, or by replying to a message from a Mentor, you agree to the disclosure of your information to that Mentor. Getapy Ltd. may also provide the results of any Getapy Ltd. questionnaire you complete to Mentors, where you agree to such provision at the time of taking such as questionnaire. Getapy Ltd. may also use information provided to Getapy Ltd. via your Getapy Ltd. profiles to pre-populate connection request for you and for similar purposes.

If you have a Getapy Ltd. account, you agree that Getapy Ltd. may contact you or suggest you or your public profile to Mentors that might be interested to connect with you for a mentoring relationship on Getapy Ltd..

In addition, if you are located in the United States and your profile is public, this means that Getapy Ltd. may share all of the aforementioned information about yourself with third-parties for or on behalf of Mentors. If you do not wish to share such information, you may set your profile to private.

4.6 Sending Messages on Getapy Ltd.

Getapy Ltd. provides two-way message proxy and relay services to the users of our Getapy Ltd. products (“Relay Service”). Onboarding and other electronic communication services whether in the form of text, video or audio. By utilizing any Relay Service, you acknowledge that you are asking Getapy Ltd. to send these messages on your behalf. This includes your profile, minutes, chat, messages, email, responses, and other materials.

We process, monitor, review, store and analyze such content, including via automated means, for data analysis, quality control, enforcement of the Site Rules and other Getapy Ltd. policies, content moderation, and to improve the Site or any other Getapy Ltd. product or service. Examples of such improvements would be optimizing our search results, improving profile Listings, ensuring you are provided with personally relevant product features and communications, and preventing fraud and spam. As a result of this activity, or due to technical malfunction, in certain circumstances such content may be delayed or may not be delivered to the intended recipient. Getapy Ltd. may (but is not obligated to) notify you in such an event. By using a Relay Service or otherwise providing User Content through the Site, you consent to this activity and acknowledge that this activity is necessary for maintaining the quality of the Site and for providing the Relay Service.

4.7 Sending You Text Messages About Mentoring Appointments

Getapy Ltd. may offer you the opportunity to receive a text message from Getapy Ltd. when a user has scheduled a meeting or event with you or responded to your connection request via Getapy Ltd.’s email relay. In such an event you will enter your phone number on the Getapy Ltd. setting form and by entering your phone number you are representing and confirming it is your number and you have the right to accept text messages at the number. Getapy Ltd. will only send you a text message reminder for such meetings or messages through Getapy Ltd.’s email relay, and you agree to accept such text messages on your cell phone including messages sent by automated telephone dialing system. To unsubscribe at any time, reply to the text with STOP or contact Getapy Ltd. Customer Support.

4.8 Preventing Fraud and Spam

Getapy Ltd. may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Site and Getapy Ltd.’s service, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. Getapy Ltd. may investigate and disclose information from or about you or your use of Getapy Ltd. if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of the Site; or (c) may protect our rights, reputation, property, safety, or that of the public; or (d) as necessary to meet national security requirements.

For example, Getapy Ltd. is subject to the investigatory and enforcement powers of Canadian authorities, and other regulatory bodies.

We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users.

– Preventing Fraud and Spam in Messages

Getapy Ltd. also reserves the right to drop messages from our relay system that Getapy Ltd. determines do not adhere to Site Rules or any of the terms of this agreement. Getapy Ltd. further reserves the right to conduct investigations to determine whether you are perpetrating a scam, spamming Getapy Ltd. or its users, or otherwise conducting fraudulent activity on Getapy Ltd. by various means, including but not limited to investigating your functionality by setting up profiles and names that belong to Getapy Ltd.. Getapy Ltd. also reserves the right to turn over any information gathered via such investigations to the police or other third party if Getapy Ltd. has a good faith belief that you are using the Site in violation of these terms.

Getapy Ltd. reserves the right to verify and confirm the identity of any party associated with an email relay. This includes but is not limited to verifying the identity of the sender of an email with the Mentor associated with that email address on the relevant profile.

4.9 Facilitating Payment

If you provide credit, debit or other payment card and related details to us in order to make a payment, Getapy Ltd. will use such information only for the purpose of processing the payment (e.g., the last four digits of credit card numbers and related verification information). Any credit card and related billing and payment information that you provide to Getapy Ltd. may be shared by Getapy Ltd. with companies who work on Getapy Ltd.’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to Getapy Ltd. and servicing your account.

4.10 Automated Processing of Your Personal Data

In order to optimize the performance of the Getapy Ltd. Site and services for users, Getapy Ltd. performs automated processing of Personal Data evaluating certain specific aspects relating to a user, in particular to analyze or predict aspects concerning a user’s personal preferences or interests in terms of Getapy Ltd.’s Site and services. Where it occurs, such processing is carried out if it is necessary for the performance of our agreement with our users, to allow Getapy Ltd. to provide its services to Mentees and Mentors, including analyzing profiles and connection requests on behalf of Mentors, or in other cases on the basis of a user’s consent.

For example, in certain cases such processing allows Getapy Ltd. to match Mentees with Mentors effectively, to provide Mentees with Newsletters and recommended profiles that the Mentee is likely to be more interested in, to send particular Mentees connection request to a Mentor, to display search results, or to perform certain spam and fraud detection activities to protect our users. Such processing is subject to the safeguards detailed in this Privacy Policy to protect the privacy of our users, and you may contact info @ getapy.com (remove spaces) to contest any decision generated by said automated processing.

4.11 Transfer of Information to Getapy Ltd. Affiliated Entities

Any information shared by you with Getapy Ltd. may be shared with or transferred to any Getapy Ltd. affiliated entity, no matter where located, for the purpose of providing you services and improving the Site, and other purposes as described in this Policy. This includes Getapy Ltd. affiliated entities located outside Canada.

Such transfers are performed in full compliance with applicable data protection rules and subject to appropriate safeguards, primarily through the use of extensive data protection agreements, in order to ensure adequate protection of users’ Personal Data. The services provided to you and the functionality of the Site could not be provided without such a transfer. If you do not wish your information to be transferred in this way you should not use this Site.

4.12 Transfer of Information to Third Parties

– Transfers to Mentors

Getapy Ltd. sends Personal Data to Mentors to which a Mentee connects and as described in sections 2 and 4 of this Privacy Policy. Such Personal Data will be processed in accordance with these terms and those of the relevant Mentor. Mentees that connects to Mentor profiles through Getapy Ltd. that are outside their own country may involve sending their Personal Data to countries with lower levels of data protection.

Mentor account holders agree to comply with all their responsibilities under applicable data protection rules with respect to the collection, processing and storage of Personal Data, as well as providing adequate protection of all data subject rights provided for under all applicable data protection rules.

– Transfers to Service Providers and Vendors

We may use third parties to perform services in connection with our operations, to improve the Site and our services, products, and features, to protect our users and better understand their needs, and to optimize the services and the users’ experiences. These third parties may include (but are not limited to) service providers and vendors.

These third parties may provide data points including how much time you spend on specific pages, which links you choose to click, and data that helps determine user preferences. This information enables us to build and maintain our services with user feedback. These third parties may use cookies and other technologies to collect data on your behavior and devices such as the device type, browser information, and preferred language. An example of one of these third parties is Hotjar. To opt-out of Hotjar’s cookies, please see the link in our Cookie Policy.

Getapy Ltd. may transfer your Personal Data in limited situations to certain third-party vendors that assist Getapy Ltd. with protecting our users and maintaining the quality of our services, products and features provided to those users. An example would be vendors Getapy Ltd. uses for fraud detection purposes. Examples of those vendors include: SiftScience and Emailage.

Getapy Ltd. may also share any credit card and related billing and payment information that you provide to Getapy Ltd. with companies who work on Getapy Ltd.’s behalf, such as payment processors and/or credit agencies, solely for the purposes of checking credit, effecting payment to Getapy Ltd., effecting payment from Getapy Ltd. and servicing your account. Examples of those vendors include: Stripe.

Getapy Ltd. may additionally share your Personal Data with service providers when you download, install and/or use the Getapy Ltd. App. This may be done for a variety of purposes, including facilitating user log-in through third party accounts or ad attribution. When you download or install a Getapy Ltd. App, you acknowledge and accept that your Personal Data may be transferred to these service providers. Examples of the types of technologies that may support this behavior include software development kits (SDKs), pixels, javascript snippets, or cookies.

In the course of providing these services, those companies may have access to Personal Data, and this may involve transfers of such Personal Data to other countries. Such transfers are only made for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable and necessary. Those companies are also contractually required to treat such Personal Data in accordance with this Privacy Policy, and in accordance with all applicable laws with respect to such transfers and any processing performed by those third parties on such Personal Data.

– Transfers to Cloud Service Providers

Please also be aware that we may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.

– Transfers of Publicly Available Information

When users post content on Getapy Ltd. in a manner that is intended to make that content publicly available and searchable by individuals, Getapy Ltd. reserves the right to aggregate and share that information with third parties. For example, if a user adds content or their profile on Getapy Ltd., Getapy Ltd. may share that information with third parties, at Getapy Ltd.’s discretion and subject to agreement between Getapy Ltd. and any such third parties. Getapy Ltd. also reserves the right to share information aggregated from public sources in this capacity.

– Third-Party Sites You Link to from Getapy Ltd.

You may also use certain third-party sites or services that you link to from Getapy Ltd.’s Site. In such cases, all information you provide to a third party is provided to that third party and not to Getapy Ltd., and is subject to the third-party’s privacy policy and terms of service. Please see section 8 of this Privacy Policy titled Links to Third-Party Sites for more information.

– Installing or Using the Getapy Ltd. App

In order to provide you with certain services and support ad attribution, limited user data may be shared with certain service providers when you install, download or use the Getapy Ltd. App. This may include your IP address or other unique identifier, and event data related to the installation of the Getapy Ltd. App.

This may be done for a variety of purposes, including facilitating user log-in through third party accounts. It may also assist Getapy Ltd. to understand and optimize our users’ complete customer journey by helping us: (i) understand how users arrive to Getapy Ltd.; (ii) better measure the performance of ads, content or other information; and (iii) understand where a user has accessed Getapy Ltd. through different devices.

When you download or install a Getapy Ltd. App, you acknowledge and accept that your Personal Data may be transferred to these service providers. You also agree to Getapy Ltd.’s Cookie Policy, Privacy Policy and Terms of Service, and are informed that you may avail of your rights at any time, as detailed in section 10 of this Privacy Policy, including the right to object to the legitimate interest use of your personal data for marketing purposes.

Examples of the types of technologies that may support this behavior include software development kits (SDKs) (such as Facebook SDK), pixels, javascript snippets, or cookies.

– Transfers of Personal Data for individuals outside of Canada or your country of residence

Please see sections 11 and 12 of this Privacy Policy for information related to this.

5. Additional Uses and Disclosures of Non-Personal Data

In addition to the other uses and disclosures of information set forth in this Privacy Policy, and notwithstanding anything in this Privacy Policy to the contrary, we may use and disclose, for any purpose, any Non-Personal Data, except where we are required to do otherwise under applicable law. If we combine any Non-Personal Data with Personal Data, then we will only use and disclose such combined information for the purposes described in sections 4 and 9 of this Privacy Policy while it is so combined.

6. Security

Getapy Ltd. seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Getapy Ltd.’s control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails,chat, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.

Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies. Please see section 11 of this Privacy Policy for liabilities pertaining to the transfer of Personal Data of individuals outside of Canada or your Country of residence

7. Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Please see our Cookie Policy for further information regarding Getapy Ltd.’s use of Cookies.

8. Links to Third-Party Sites

The Site may make available links to other websites. When you click on such links, you may leave our Site. Your web browser may also disclose to the third party site the URL of the Getapy Ltd. page you clicked from, and this URL may include search terms and filters you used on Getapy Ltd.. The Site may also make available Pages, which may contain information provided by third-party.

WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY MENTORS (INCLUDING ANY MENTOR THAT PROVIDES AN EXTERNAL PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.

9. Acquisitions and Other Reorganizations

Information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any change of ownership or control in Getapy Ltd.’s business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business and assets (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy. Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger carried out by Getapy Ltd. of such third parties.

10. Exercising Rights With Respect to Personal Data

Getapy Ltd. users that provide their Personal Data to Getapy Ltd. may avail of the rights detailed below.

10.1 The Right to Rectify Your Personal Data

Getapy Ltd. users are able to edit and update most of their Personal Data held by Getapy Ltd. on the Site, and if you have any queries or complaints we encourage you to contact us here.

Alternatively, if you do not wish to do this you may make a formal request to have Getapy Ltd. rectify any inaccurate Personal Data on your behalf by sending an email to info @ getapy.com (remove spaces when sending email) from the email address associated with your account.

10.2 The Right to Object to or Restrict the Processing of Your Personal Data

If you have any queries or complaints about how we process your Personal Data we encourage you to contact us here.

Alternatively, if you do not wish to do this you may make a formal request to object to, or restrict, processing of your Personal Data by Getapy Ltd.. For example, you have the right to object to the legitimate interest processing of your Personal Data by Getapy Ltd. for marketing purposes. In order to do so please send an email to info @ getapy.com (remove spaces when sending email) from the email address associated with your account.

10.3 Opting Out of Marketing Messages and Withdrawing Consent

Getapy Ltd. performs consent-based processing of your Personal Data in limited circumstances, as detailed in section 2.6 of this Privacy Policy. If you no longer want to receive marketing materials from us based upon your Personal Data, you may opt out of receiving such marketing related messages by clicking unsubscribe (or an equivalent action) where applicable. Please note that we may still send other messages to you, such as administrative messages. You may withdraw your consent for any other consent-based use of your Personal Data by Getapy Ltd. by sending an email to info @ getapy.com (remove spaces when sending email). In your message, please detail which activities from which you wish to withdraw your consent. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws.

10.4 The Rights of Access to and Portability of Your Personal Data

Getapy Ltd. users are able to access most of their Personal Data held by Getapy Ltd. on the Site, and if you have any queries or complaints we encourage you to contact us here.

Alternatively, if you do not wish to do this you may make a formal request to access your Personal Data held by Getapy Ltd.. In order to do so, please send an email to info @ getapy.com (remove spaces when sending email) from the email address associated with your account, and paste the following sentence in your email: “I am requesting to access my personal data.” Getapy Ltd. will provide your Personal Data to you in a portable format to allow it to be transmitted to third parties. If you have interacted with Getapy Ltd. using more than one email address, please send a subsequent from the additional email addresses so that we may provide this personal data as well.

10.5 The Right to Delete Your Personal Data

Getapy Ltd. users are able to edit and update most of their Personal Data held by Getapy Ltd. on the Site, and if you have any queries or complaints we encourage you to contact us here.

Alternatively, if you do not wish to do this, you may make a formal request to delete your Personal Data held by Getapy Ltd.. In order to do so, please email to info @ getapy.com(remove spaces when sending email) from the email address associated with your account, and paste the following sentence in your email: “I am requesting to delete my personal data.” Once your request has been confirmed, Getapy Ltd. will initiate the necessary steps to execute this exercise, including the deletion of your Getapy Ltd. account. Where the deletion request relates to Personal Data that you previously requested be made public on Getapy Ltd. (e.g. a Mentee adds a public profile), we will make reasonable efforts to inform any other controllers of this request. If you have interacted with Getapy Ltd. using more than one email address, please send a subsequent from the additional email addresses so that we may delete this personal data as well.

PLEASE NOTE: by requesting the deletion of your Personal Data, you will no longer be able to create an account with Getapy Ltd. using the same email address. If you simply wish to close your account, please click the “cancel my account” button in your account page. Additionally, if you use Getapy Ltd. for a connection requests or take any other action on the Site using the same email address associated with your deletion request, you may not receive certain communications associated with those actions from Getapy Ltd. or other Getapy Ltd. users.

10.6 Some Limitations

Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which starts to run from the point of Getapy Ltd. confirming your request. Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by Getapy Ltd. and only imposed to the extent permitted by applicable law.

11. Personal Data from Individuals outside of Canada or in the EU and Switzerland

11.1 Privacy Shield Principles and Framework

Getapy Ltd. transfers certain Personal Data to suppliers and vendors outside Canada. Getapy Ltd., complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the EU member countries and Switzerland to the United States. Getapy Ltd. has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity, and Purpose Limitation, Access, Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

11.2 Principle of Onward Transfer

In the context of an onward transfer of data to a third party, a Privacy Shield organization has responsibility for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Getapy Ltd. shall remain liable under the Principles if its agent processes such Personal Data in a manner inconsistent with the Principles, unless Getapy Ltd. proves that it is not responsible for the event giving rise to the damage.

11.3 GDPR Protections

Getapy Ltd. transfers made according to the Privacy Shield Framework are performed based on agreements that also incorporate the protections and requirements provided for under Chapter V (and Article 28, where appropriate) of the GDPR. This incorporates EU data protection requirements to ensure adequate protection of such personal data transfers.

12. Independent Dispute Resolution For Individuals in the EU and Switzerland

In compliance with the US-EU and Swiss-US Privacy Shield Principles, Getapy Ltd. commits to resolve complaints about your privacy and our collection or use of your Personal Data. EU and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Getapy Ltd. at: Getapy Ltd. Privacy Program, Getapy Ltd., 802-57 Macaulay Av. M6P 3P5 toronto, Ontario, Canada, or by emailing info @ getapy.com (remove spaces when sending email).

13. Do Not Track Requests

We do not respond to the browser “Do Not Track” (DNT) signal if enabled by the user in their web browser. When we set or read cookies on non-Getapy Ltd. sites that have integrated our services and display features, we do so, for example, to provide a personalized profile search experience to users on those sites. We do not share any information about your use of Getapy Ltd. with those third parties. When third parties that we have integrated into Getapy Ltd. sites (as described in the Getapy Ltd. Cookie Policy) set or read their own third-party cookies, they may or may not respond to the DNT signal.

14. General Inquiries and Complaints

14.1 Contacting Getapy Ltd.

You may contact Getapy Ltd. at 802-57 Macaulay Av. M6P 3P5 toronto, Ontario, Canada, or you may contact either company via our Site contact form. If you would like to contact Getapy Ltd.’s Data Protection Officer, please send an email to info @ getapy.com (remove spaces when sending email).

14.2 Complaints

If you believe your data protection rights have been infringed by Getapy Ltd., you have the right to complain to the appropriate data protection supervisory authority in your jurisdiction. For example if you are in Canada, Getapy Ltd.’s main establishment in Canada is Getapy Ltd., and it is regulated by the Office of the privacy Commissioner of Canada , in which case you should consult this link for these purposes. If you are in the EU or Switzerland and have a complaint with respect to transfers and processing performed in accordance with EU-US and Swiss-US Privacy Shield Principles then you may avail of independent dispute resolution, either via the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada.

15. Your California Privacy Rights

Under California’s “Shine the Light” law (Civil Code section 1798.83), California residents have certain rights regarding the disclosure of their Personal Data to third parties for their own direct marketing purposes. Getapy Ltd.’s policy is not to disclose your Personal Data to third parties for the third parties’ direct marketing purposes if you have exercised your option to prevent that information from being disclosed to third parties for those purposes. If you wish to not have your personal information shared for those purposes, you may request that Getapy Ltd. delete your Personal Data by following the steps outlined in Section 10 of this Privacy Policy.