March 28, 2022

Privacy Policy

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PRIVACY POLICY

[Last Amended: March 19, 2024]

This privacy policy (“Privacy Policy”) describes how Pixellot Ltd. (collectively with its affiliated companies shall be referred to herein as the “Company”, “we”, “us” or “our”) collects, uses and discloses certain information, including Personal Data (as defined below) and the choices you can make about such information.

This Privacy Policy governs the processing and transfer of Personal Data, directly or indirectly, when using the Company’s AI-automated sports camara, streaming, broadcasting and analytic services, video analysis platform, video editing platform, etc. (“Services”), visiting the website https://www.pixellot.tv/, or other landing pages and the content therein (“Website“) or when applying for an open position published on the Website (“Applicant“). Unless otherwise stated herein, customers, prospect, visitors and Applicant shall be separately and collectively referred as “you” or “your“.

The Website, hardware (i.e., cameras), software and platforms, shall all collectively be referred as “Company Properties“.

This Privacy Policy is an integral part of the terms and conditions governing any use of the Website, apps or hardware, as well as any agreement executed between us governing the use of the Services or interaction with the Company’s Properties (“Terms”), capitalized terms not defined herein shall have the meaning ascribed to them in the Terms.

Note you are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.

This Privacy Policy applies to all individuals in applicable territories; however, certain territories require certain disclosures to be provided in a certain way and format, meaning, we do not process the information differently however there might be differences in the disclosures, as follows:

Additional Information to California Residents: In the event you are a California resident– please also review our CCPA Privacy Notice to learn more about our privacy practices with respect to the California Consumer Privacy Act.

Additional Notice to Colorado, Virginia, Connecticut or Utah Residents: In the event you are a resident of one of these US states – please also review Section 12 below ”Jurisdiction-Specific Notices” to learn more about our privacy practices and your rights under the privacy and data protection legislation which applies in these states.

1. AMENDMENTS

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the Website and the update date will be reflected in the “Last Amended” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

2. CONTACT INFORMATION AND DATA CONTROLLER INFORMATION

The Company, incorporated under the laws of the state of Israel, is the Controller (as such term is defined under applicable data protection laws including the EU General Data Protection Regulations (“GDPR”)) of the Personal Data.

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact as follows:

The Company’s data protection officer (“DPO”): Mr. Eran Gutman, at EranG@Pixellot.tv

By email: privacy_pixellot@pixellot.tv

By mail: Granit 11 St. Petach-Tikva, Israel.

3. DATA PROCESSED BY THE COMPANY

We may collect two types of information from you, depending on your interaction with us.

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system, type of device, time and date accessed the Service, language preference, screen resolution, or aggregated data and insights which do not personally identify or could identify an individual.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data” or “Personal Information” as defined under the applicable data protection law).

For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

As detailed below, we may also collect or process sensitive Personal Data constituting photograph, or revealing bio-metric data of athletes that may also be children, etc. (“Special Categories of Personal Data”).

When using our Services, we may collect and process facial recognition information of athletes through our facial recognition software, which allows for specific individuals including Childrens to be detected in photographs and videos. Depending on the applicable laws, some of the information collected by the facial recognition feature may be considered “biometric data“. Customers will be able to opt-out of such data collection by opting out of the facial recognition feature altogether. Face recognition related-data, including biometric data that we collect from athletes, will only be used to provide Services. The biometric data will be stored securely in our database and will only be retained for as long as required by applicable law.

We will not sell, lease, trade or otherwise profit from Personal Data that constituted as Special Categories of Personal Data, nor will any of our vendors, service providers or partners who have access to such data be permitted to do so.

The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:

Type of Data

Purposes and Operation

Lawful Basis under the GDPR

Contact Information:

In the event you contact us with any inquiries, newsletter registration, requesting a demo or meeting, you will be requested to provide us with contact details such as your full name email address, phone number, company name, address, etc. In addition, you can choose to provide us with additional information as part of your correspondence with us (“Contact Information“).

We will process the Contact Information to provide you with a response to your inquiry or improving such features and communication.

We will process Contact Information subject to our legitimate interest.

In the event you register to receive our newsletter, we will use your Contact Information subject to your consent.

Account Information:

When you create an account and sign up for our Services you will be requested to provide us with certain information such as sport type, your full name, email address, telephone number, designated password, role, etc. (“Account Information“).

IF we will allow registration through your social media account (such as Gmail or Facebook account), we will receive from such third party certain details for registering you, as your name, email and other details per such third party privacy practices.

We use the Account Information to create your account, authentication, provide account management (including billing and invoices), customer support and to provide the Services.

In addition, we use your email address in order to provide you with marketing related communication such as new features, additional offerings, special opportunities or any other information we think our customers will find valuable (“Direct Marketing”).

We process your Account Information for the performance of our contract with you or, depending on your interaction with us, in order to take steps prior to entering into such contract.

Where we use you email address for direct marketing purposes, such processing is subject to our legitimate interest. Note you can opt-out at any time from Direct Marketing through the “unsubscribe” link within the emails we send you. Note however that if you choose to opt-out from Direct Marketing, we will further maintain a suppression file – meaning lists of applicable email addresses that have requested to opt-out, under our legitimate interest and to ensure we comply with such preference and choice.

Customer Support

When our customers contact us for customer support, we will process your Contact Information

We will use Contact Information to provide the customer support needed. We will retain such correspondence for as long as needed, and to evidence the support was provided.

We process such information for performing our contract with you.

Usage Data:

When you use the Service, information regarding such use is automatically generated and collected, which may include the click stream within the Service, the time spent on each page or feature, crash data and analytics, how often you use the Service, etc. (“Usage Data“). Usually, the Usage Data is associated with an Online Identifier, and thus, would be considered as Personal Data, further access logs may include the name, user name, email, and time and data accessed.

We use your Usage Data to help us understand how you are using our Services, and how to better provide and improve our Services. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and Platform. We also use your Usage Data for statistical analysis purposes, to test and improve our Services.

We process your Usage Data subject to our legitimate interest.

Athlete Data & Video Footage:

In order to use the Services, you might be required to provide us with information of your athletes, including: full name, email address other information you decide to provide us. in addition, our Services include processing video footage that will and might include Personal Data or even Sensitive Data, such as players face, audience face, including children, movement and physical shape, names and Contact Information, etc.

We will use this data to provide the Services.

We will process the Tracking and Video Coverage Data as a “processor” (or the equivalent term as defined under applicable Data Protection Laws) on behalf of our customer, for the sole purpose of providing our Services to the customers.

Recruitment Information:

‍When applying for a position offered by the Company, we will process the CV you provided including any information associated therewith, such as your name, email address, phone number, your education and skills, employment history, and your photo (to the extent provided by you).

Further, where required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability.

In addition, we may collect further information from public and online sources, referees, and former employers and combine such data with your other data.

(Collectively “Recruitment Information”).

We will collect Recruitment Information in order to process your application, for recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements.

If you are hired, your Recruitment Information may be stored with HR as part of your employee file, and subject to our corporate management.

We use JazzHR as our third party service provider to manage job applications. Such vendor is contractually obligated to keep your information confidential and secure and it will not use the Recruitment Information for any other purpose other than detailed herein, all in accordance with JazzHR privacy policy available here.

We process Recruitment Information subject to our legitimate interest.

In some cases, for example, where we will ask you to provide health related information or diversity and inclusion data, we will process such data based upon your consent. You may always withdraw consent at any time.

We will retain your Recruitment Information for records keeping and future defense from legal claims under our legitimate interest, or if you have provided consent to contact you in the future.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the Data Transfer section below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

4. HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

Information you provide us directly – for example, when you register and create an account or correspond with us.
Information we receive from third parties – for example, we receive Non-User Data directly from our Customers.
Information we receive automatically – we will collect your Online Identifiers and Usage Data including analytics data (or use third-party measurement and marketing tools) automatically. For more information on the cookies we use and how to opt out of third-party collection of this information, please see our Section 5 below “Cookies & Tracking Technologies”.

5. COOKIES & TRACKING TECHNOLOGIES

We use “cookies”, Software Developer Kits (aka ‘SDKs’) (or similar tracking technologies) when you access the Company’s Properties or interact with the Services we offer. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, as well as for advertising purposes.

You can find more information about our use of cookies under our Cookie Policy, as well as change your settings and preferences at any time by using the Cookie Settings tool available on Company’s Properties footer.

6. SHARING DATA WITH THIRD PARTIES

We share your Personal Data with third parties, including our service providers that help us provide our Services. You can find in the table below information about the categories of such third-party recipients.

CATEGORY OF RECIPIENT	DATA THAT WILL BE SHARED	PURPOSE OF SHARING
Service Providers	All types of Personal Data	We employ other companies and individuals to perform functions on our behalf, such as sending communications, processing payments, analyzing data, providing marketing and sales assistance (including advertising and event management), identifying errors and crashes, conducting customer relationship management, etc. These third-party service providers have access to Personal Data which is strictly necessary needed to perform their functions, and are prohibited from using your Personal Data for any purposes other than providing us with requested services.

Affiliated Companies

All types of Personal Data

We may share certain information with our affiliated companies, for sales and marketing purposes, for internal compliance and measurement.

Any acquirer of our business

All types of Personal Data

We may share all types of Personal Data in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In such event, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Governmental agencies or authorized third parties

Subject to law enforcement authority request.

We may share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, governmental agencies or authorized third parties, or protect the rights, property, or Company security of the, our Customers or others.

We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.

7. YOUR RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

In the table below you can review your rights depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table:

RIGHT TO BE INFORMED	You have the right to be provided with information regarding our Personal Data collection and privacy practices. All is detailed under this Privacy Policy
RIGHT TO KNOW; ACCESS RIGHTS	You have the right to confirm whether we collect Personal Data about you, know which Personal Data we specifically hold about you, and receive a copy of such or access it. If you wish to receive a copy of the Personal Data, please submit a Data Subject Request form as instructed below.
RIGHT TO CORRECTION/ RECTIFICATION	You have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. Please submit a DSR as instructed below.
RIGHT TO BE FORGOTTEN; RIGHT TO DELETION	In certain circumstances, you have the right to delete the Personal Data we hold about you. For specifications regarding this right and its exclusions, or if you wish to exercise this right, please submit a DSR as instructed below.
RIGHT TO PORTABILITY	You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please submit our DSR as instructed below.
RIGHT TO OPT OUT UNDER THE EU (I.E., WITHDRAW CONSENT OR RESTRICT THE PROCESSING), AND SPECIFICALLY IN THE US – THE RIGHT TO OPT OUT FROM: (I) SELLING PERSONAL DATA; (II) RIGHT TO OPT OUT FROM TARGETED ADVERTISING; AND (III) RIGHT TO OPT OUT FROM PROFILING AND AUTOMATED DECISION MAKING	Direct Marketing: You have the right to opt-out from Direct Marketing, by unsubscribing through the email received. Cookies: When you no longer wish for cookies to track your behavior for analytic and marketing purpose, change your preferences through the cookie settings available on the applicable Company’s Property.
RIGHT TO APPEAL OR LODGE A COMPLAINT	If we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the EU you have the right to lodge a complaint with the supervisor authority or the Information Commissioner in the UK.
NON-DISCRIMINATION	Such discrimination may include denying a service, providing a different level or quality of service, or charging different prices. We do not discriminate our customers or users.

If you wish to exercise any of your rights, you can approach us through our means or contact, by sending us our Data Subject Right form, available here.

8. DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.

Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (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. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

9. SECURITY

We design our Services while your security and privacy in mind. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry standards.

Please contact us at: privacy_pixellot@pixellot.tv, if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

10.DATA TRANSFER

Your Personal Data processed by the Company is processed and stored by other entities, services providers, legal authorities, etc. as detailed above. Therefore, your Personal Data might be transferred to jurisdictions other than the jurisdiction from which you accessed our Services; and while the data is in the other jurisdiction, it may be accessed by the courts, law enforcement, and national security authorities. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer. If and where Personal Data collected within the EEA is transferred outside the EEA, we will do so pursuant with the standard contractual clauses approved by the European Union (“SCCs“). Additionally, following Brexit the UK is no longer considered to be a part of the EEA and therefore, the transferring of Personal Data from the EEA to the UK will also be subject to the SCCs or other contractual clauses that will ensure the security of the Personal Data (pending an adequacy decision from the European Commission).

11.CHILDREN

The Website is intended for general audience and is not directed to individuals under 18 years old. If any of your data subjects (e.g. athletes) are minors under the age of 18, you must obtain parental consent prior to using our Services. The Company will not knowingly contact or engage with children under the age of 18 without said parental consent. If you have reason to believe that a child has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases.

12.JURISDICTION-SPECIFIC NOTICES

A. ADDITIONAL INFORMATION FOR COLORADO RESIDENTS

This section applies to Colorado residents acting only as an individual or household context (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context).

Under the Colorado Privacy Act (“CPA”), the Company is required to provide a privacy notice that identifies the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 7 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy_pixellot@pixellot.tv and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/

If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.

Any disclosures we provide will only cover the 12-months period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

B. ADDITIONAL INFORMATION FOR CONNECTICUT RESIDENTS

This section applies to Connecticut residents acting only as an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity).

Under the Connecticut Data Privacy Act (“CDPA”), the Company is required to provide you with a clear and accessible privacy notice that includes the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 7 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising.

We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests and we inform you of such extension within the initial 45 days response period, together with the reason for the extension. If we decline to take action on your request, we shall so inform you without undue delay, within 45 days of receipt of your request. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy_pixellot@pixellot.tv and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.

We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.

C. ADDITIONAL INFORMATION FOR VIRGINIA RESIDENTS

This section applies to Verginia residents acting only as an individual or household context (and not in an employment or commercial context).

The Virginia Consumer Data Protection Act (“VCDPA”) requires the Company to disclose the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 7 to this Privacy Policy details and discloses your rights and Personal Data shared or sold for targeted advertising.

We will respond to your request within 45 days after receipt of a verifiable Consumer Request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at privacy_pixellot@pixellot.tv and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.

D. ADDITIONAL INFORMATION FOR UTAH RESIDENTS

This section applies to Utah residents acting only as an individual or household context (and not in an employment or commercial context).

Under the Utah Consumer Privacy Act (“UCPA”), the Company is required to provide you with a clear and accessible privacy notice that includes the following: in Section 3 to the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent. Additionally, Section 6 to this Privacy Policy details and discloses the categories of third-parties we share for business purposes. Section 7 to this Privacy Policy details and discloses your rights if and to the extent applicable under the UCPA.

We will respond to your request within 45 days after receipt of your request (no more than twice in a twelve-month period). We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, we will provide with the reasoning for our refusal.