Privacy Policy

Date of Last Update: May 13, 2021

By visiting, viewing, accessing, browsing, surfing or using (__“using”__ or __“use”__) our website [www.easyadm.com](https://www.easyadm.com) including its sub-domains and mobile-optimized version (__“Website”__) or using our mobile application named "EZ Gmail Reader" or "Easy AI" (__“App”__), you (__“you”__, __“your”__ or __“User”__) consent to the data collection, revealing and use practices as delineated in this Privacy Policy. The Website and App are owned by Mr. Ilan Laloum, having his business address registered at HaGolan 6, Israel. 4275845 (__“we,”__ __“us”__ or __“our”__). Additionally, this Privacy Policy sets out how we might collect, reveal or use data relating to Users.

1. __Information We Collect__

1.1 The App can be downloaded from Google Workspace Marketplace. The App uses ‘Google APIs’ and gives the administrator of a Google Workspace domain control over the activities of users having e-mail accounts in that domain. Broadly speaking, the App allows such administrator to: (i) read any e-mail content of any user of the domain, (ii) download e-mail content of any user of the domain, and (iii) search any content in any mailbox in the entire domain, anonymously and without knowing password of a user. Further, some of the key features of the App include: (a) cross multiple account search with live results, (b) view e-mail body in full HTML format, (c) download any attachment from any e-mail message, (d) activity summary for the last Day/Week/Month, and (e) states reports for the system administrator. To use the App, the Users can sign up to the App with Google identity. The App then offers access to a password protected profile to our Users wherein they can use all features of the App. For this purpose, the following types of Personal Data, Payment and Invoicing Data, Communication Data, Technical Data and Marketing Data (collectively the __“Data”__) may be collected from Users user suing the App or the Website:

1.1.1 __Personal Data:__ Includes Name, E-mail Address and Google Profile Picture as well as such other data as may be deemed necessary for providing the App Services.

1.1.2 __Payment and Invoicing Data:__ Credit/Debit Card Number, Card Brand, Expiration Date, payment transactions, banking information, etc.

1.1.3 __Communication Data:__ Includes data that you provided us through the consultation/application/contact form on the App, through e-mail or otherwise. The lawful ground for this processing is our legitimate interests such as to reply to communications sent to us, to keep records and to establish, pursue or defend potential legal claims.

1.1.4 __Technical Data:__ Technical Data includes data regarding your use of the App and the App services such as your IP address, login, browser details, details of visit of pages on the App, page views and navigation details, usage amount, time zone settings and other technical information on your device. The lawful ground for this processing is our legitimate interests such as to enable us to properly administer the App and our business and to grow our business.

1.1.5 __Marketing Data:__ Includes data about your preferences in receiving marketing material from us and our nominated third parties. The lawful ground for this processing is our legitimate interests such as to assess how Users use the App services, to develop them, to grow our business and to decide our marketing strategy.

2. __Name and Address of the Data Controller__

2.1 The Data Controller relating to the General Data Protection Regulation (__“GDPR”__) and other data protection laws applicable in the Member States of the European Union (__“EU”__) is:

: Data Protection Officer: Ilan Laloum

: Address: HaGolan 6, Israel. 4275845

: Phone: +1-929-560-0376

: Email: [contact@easyadm.com](mailto:contact@easyadm.com)

: Website: [www.easyadm.com](https://www.easyadm.com)

3. __Consent and its Withdrawal__

3.1 Your consent to process your Data is deemed granted when you use the App or the App services or fill the forms available on the App. It is necessary for us to collect all necessary Data from you for the purposes of providing the App services.

3.2 Your Data will be processed only after taking your consent in the form of a Clickable button or a checkbox when you accept the Privacy Policy.

3.3 You may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at contact@easyadm.com.

4. __Usage and Data Processing__

4.1 Your Data may be used to provide you the App services and better understand your needs in relation thereto, to reply to any of your questions and requests regarding the App services and to provide required consulting / coaching to Users.

4.2 Your Data is not rented or sold to others.

4.3 You are deemed to have authorized us to use your Data for the following purposes:

: i. Compile anonymous statistical data and analysis for use internally or with third parties;

: ii. Create and manage your account;

: iii. Manage purchases, orders, payments and processing transactions through the App;

: iv. verifying your identity;

: v. Generate a personal about you to make future visits to the App more personalized;

: vi. providing you the App services and responding to your queries, feedback or disputes;

: vii. making such disclosures as may be required for any of the above purposes or as required by applicable laws and regulations or in respect of any subpoena, investigations, claims or potential claims brought on or against us;

: viii. sending you notices regarding services you are receiving and for billing and collection purposes;

: ix. providing and maintaining the App services;

: x. improving the App such as through personalized features and content;

: xi. Increase the efficiency and operation of the App;

: xii. Monitor and analyse usage and trends to improve your experience with the App;

: xiii. Notify you of updates to the App;

: xiv. Offer new products, services, mobile applications, and/or recommendations to you;

: xv. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity;

: xvi. Process payments and refunds;

: xvii. Request feedback and contact you about your use of the App;

: xviii. Resolve disputes and troubleshoot problems;

: xix. Respond to product and customer service requests; and

: xx. Solicit support for the App.

4.4 It shall be ensured that:

: i. Your Data collected by us or any of our third party will be used as per applicable data privacy laws;

: ii. The reasons for the collection of Data and its usage will always be made known to you;

: iii. Only the necessary Data will be collected from you;

: iv. If any Data submitted by you online cannot be fully deleted at your request under normal circumstances, you will be informed accordingly;

: v. Necessary technical and organizational measures are used to protect your Data; and

: vi. Your Data is transferred securely;

5. __Criteria for Disclosure of Data__

5.1 Your Data will not be kept private in response to the legal process. If we deem that an investigation is required, an action is warranted in order to prevent illegal activities or suspected fraud, avert threats to the physical safety of a person, stop violation of our Terms or as otherwise required by law, we may disclose your Data. Moreover, your Data may also be disclosed in case of takeover, merger or acquisition.

5.2 Your Data may be disclosed in the good faith belief that an action is necessary to:

: i. comply with a legal obligation;

: ii. protect and defend our rights or property;

: iii. prevent or investigate possible wrongdoing;

: iv. protect safety of our users and general public;

: v. protect against legal liability.

5.3 Your Data may be disclosed or transferred to our professional advisors, law enforcement agencies, insurers, government, and regulatory and other organizations in case of need.

5.4 We may share your information with third-party service providers that perform services for us or on our behalf such as payment processing and data analysis. We are not responsible for the actions of such third-party service providers with whom you share personal or sensitive data and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, e-mails or other communications from third-party service providers, you are responsible for contacting the third party directly.

5.5 If we reorganize or sell all or a portion of our assets, undergo a merger or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honour commitments we made in this Privacy Policy.

6. __Data Storage__

6.1 We will store and process your Data at our dedicated server Microsoft Azure (Cloud).

6.2 We act as the controller and our above partners as processors, meaning they will not undergo Personal Data processing activities towards information registered, submitted or conveyed by us.

6.3 Your Data may be transferred to our affiliated entities or other third-parties across borders. You hereby give consent to such transfer.

6.4 Your Data will be retained for as long as necessary to fulfil the purposes we collected it including to satisfy any record retention or reporting requirements under applicable laws.

6.5 As herein above mentioned, we will maintain Personal Data pertaining to our Users for the duration of the App services and as per legal requirements.

7. __How We Protect Your Information__

7.1 While we strive to use commercially acceptable means to protect your Data, we cannot guarantee its absolute security since no method of transmission over the Internet or method of electronic storage is 100% secure.

7.2 While we are concerned with protecting privacy of your Data, we do not give any guarantee to the security of your Data.

7.3 Your Data will be retained by us and will be accessible by our employees and any third-party service providers engaged by us.

8. __Tracking Technologies__

8.1 Cookies and Web Beacons

8.1.1 We may use cookies, web beacons, tracking pixels and other tracking technologies on the App to help customize the App and improve your experience. When you access the App, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the App. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

8.2 Website Analytics

8.2.1 We may also partner with selected third-party vendors, such as Google Analytics to allow tracking technologies and remarketing services on the App through the use of first-party cookies and third-party cookies, to, among other things, analyse and track users’ use of the App, determine the popularity of certain content, and better understand online activity. By accessing the App, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

9. __Third-Party Websites__

9.1.1 The App may contain links to third-party websites and applications of interest, including advertisements and external services that are not affiliated with us. Once you have used these links to leave the App, any information you provide to these third parties is not covered by this Privacy Policy and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third-party responsible for that website and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the App.

10. __Controls For Do-Not-Track Features__

10.1.1 Most web browsers and some mobile operating systems include a Do-Not-Track (__“DNT”__) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

11. __Options Regarding Your Information__

11.1 Account Information

11.1.1 You may at any time review or change the information in your account or terminate your account by:

+ Logging into your account settings and updating your account.

+ Contacting us using the contact information provided below.

11.1.2 Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

11.2 Emails and Communications

11.2.1 If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

+ Noting your preferences at the time you register your account with the App.

+ Logging into your account settings and updating your preferences.

+ Contacting us using the contact information provided below.

11.2.2 If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

12. __Compliance with the GDPR__

12.1 We will make all reasonable efforts to ensure that the Website and the App comply with the General Data Protection Regulation (GDPR) (EU) 2016/679 of the EU regarding the collection, use and retention of Data from the Users based in European Union’s Member States. We will also make all reasonable efforts to adhere to the GDPR requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.

12.2 We strictly observe Article 14 ruling of the GDPR, making explicitly known to the user which Personal Data we have gathered pertaining to him / her and what has been the source as well as the __“purpose”__ and __“scope”__ of our Personal Data processing activities.

12.3 Per Article 14 of the GDPR, if either the user provides no feedback or he/she declines to approach / contact, we shall erase the Personal Data that we have gathered until one (1) month after collection date.

12.4 To prevent further contact within the same scope, the user’s name and e-mail address will be ‘blacklisted’ in our records that is accessible to our relevant internal departments only.

12.5 Personal Data pertaining to any User that is identified as being under eighteen (18) years of age (therefore not bearing full legal capacity as an adult) will be automatically excluded from our records. This also comprehends the unlikely event of a user who is under eighteen (18) years of age but has been identified as an adult by error / mistake/ his / her own conduct.

12.6 Upon the collection of Personal Data pertaining to Users, we will identify the User by asking further information, if required.

12.7 The Rights of Users: Users based in EU may exercise following rights regarding their Data:

(i) Right of confirmation: Users shall have the right to obtain confirmation from us as to whether or not your Personal Data is being processed.

(ii) Right of Access: Users shall have the right to obtain free information from us about their Personal Data as well as its copy at any time. The EU directives and regulations also grant you access to the following information:

+ the purpose of the processing;

+ the categories of Personal Data concerned;

+ the recipients or types of recipients to whom your Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;

+ the envisaged period for which your Personal Data will be stored, or, if that is not possible, the criteria used to determine that period;

+ the right to request from us rectification or erasure of Personal Data or restriction of processing of your Personal Data or to object to such processing;

+ the right to lodge a complaint with a supervisory authority;

+ where your Personal Data is not collected, any available information as to its source;

+ the existence of automated decision-making, including profiling, referred to in Articles 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for you.

(iii) Right to rectification: Users shall have the right to obtain from us without undue delay the rectification of their inaccurate Personal Data. Taking into account the purposes of the processing, Users shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

(iv) Right to be forgotten: Users shall have the right to require us to erase their Personal Data without delay which we will be obliged to do so where one of the following grounds applies as long as the processing is not necessary:

+ The Personal Data is no longer required.

+ You choose to withdraw your consent as per sub-article (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR.

+ As per Article 21(1) of the GDPR, you raise any objection against the processing of your Data and when there is no overriding ground for such processing or you raise objection pursuant to Article 21(2) of the GDPR.

+ The Personal Data has been unlawfully processed.

+ The Personal Data must be erased for compliance with a legal obligation in EU or a Member State law to which we are subject.

+ The Personal Data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

+ Where we have made Personal Data public and are obliged pursuant to Article 17(1) to erase such Personal Data, we, while taking account of available technology and the cost of implementation, shall take reasonable steps including technical measures to inform other controllers processing the Personal Data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. We will arrange the necessary measures in individual cases.

(v) Right of restriction of processing: User shall have the right to obtain from us restriction of processing where one of the following applies:

+ The accuracy of the Personal Data is contested by the User for a period enabling us to verify the accuracy of the Personal Data.

+ The processing is unlawful and the User opposes the erasure of the Personal Data and requests instead the restriction of their use.

+ We no longer need the Personal Data for the processing but we are required by the User for the establishment, exercise or defence of legal claims.

+ Pursuant to Article 21(1) of the GDPR you exercise your right to object to processing when the verification process is pending.

If any of the above conditions is fulfilled and you want to restrict processing of your Personal Data stored by us, you may contact us at contact@easyadm.com.

(vi) Right to data portability: Users shall have the right to receive their Personal Data, which was provided to us, in a structured, commonly used and machine-readable format. Users shall also have the right to transmit such data to another data controller if such processing is based on consent retrieved as per point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR and the processing is carried out by automated means as long as the processing is not necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in us.

(vii) Right to object: Users shall have the right to object on grounds relating to their particular situation at any time to processing of their Personal Data, which is based on point (e) or (f) of Article 6(1) of the GDPR.

+ The Personal data will no longer be processed in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing.

+ If a User’s Personal Data is processed for direct marketing purposes, that User shall have the right to object at any time to processing of his / her Personal Data for such marketing. This applies to profile to the extent that it is related to such direct marketing. If a User objects to us to the processing for direct marketing purposes, we will no longer process the Personal Data for these purposes.

+ A User shall have the right, on grounds relating to his / her particular situation, to object to the processing of his / her Personal Data for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

12.8 Right to withdraw data protection consent: Users shall have the right to withdraw their consent to the processing of their Personal Data at any time. Users may initiate a request with us at contact@easyadm.com to exercise any of the above-mentioned rights. We shall review your request and, in our discretion, honour your request, if deemed necessary by us, within a reasonable time. Personal Data pertaining to a former Users shall be erased from our records once all applicable legal timelines have expired being that if those are dilated in time (meaning over 1 year after service termination), the Personal Data shall be securely segregated from live Data.

13. __California Civil Code__

13.1 California Civil Code, Section 1798.83, permits our Users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

13.2 If you are under 18 years of age, reside in California, and have a registered account with the App, you have the right to request the removal of unwanted data that you publicly post on the App. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the App, but please be aware that the data may not be completely or comprehensively removed from our systems.

14. __Compliance with CalOPPA__

14.1 We comply with the California Online Privacy Protection Act (__“CalOPPA”__) which requires any person or company in the United States (and conceivably the world) that requires websites collecting ‘Personally identifiable information’ from California based users to upload a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. Under CalOPPA, we agree to the following:

+ You can visit our site anonymously.

+ Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

14.2 We endeavour to fulfil requirements of the CalOPPA under this Privacy Policy in line with our policy for user data collection, storage, and disclosure as outlined for GDPR compliance.

15. Compliance of California Privacy Act 2018

15.1 This Privacy Policy is also applicable on California residents and explains how we collect, use and share your Personal Information and how you may exercise your rights under the California Consumer Privacy Act of 2018 (__“CCPA”__).

15.2 Your rights under the CCPA:

15.2.1 Under the CCPA, Users have the right to access their Personal Data during the past twelve (12) months and information about our data practices. Users also have the right to request that we delete their Personal Data.

15.2.2 To request manual access or deletion of your Personal Data, please contact us at contact@easyadm.com.

15.2.3 Please note that for making manual requests you will need to verify your identity by providing us with all the information as we may require from you for this purpose.

15.2.4 You have the right to be free from any discrimination for exercising your rights to access or delete your Personal Information.

15.3 If you have additional questions about this or how to exercise your rights under the CCPA, please contact us at contact@easyadm.com.

16. __Third-Party Service Providers__

16.1 Third party companies and individuals may be employed to facilitate operational and voice communication services ("Third Party Service Providers") in relation to providing the App Services on our behalf, to perform App Services-related services or to assist us in analysing how the App service is used.

16.2 These third parties have access to your Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

16.3 Following are third-party service providers that the Company uses that work over SSL.

+ PayPal

+ Google Pay

+ Worldnet - www.worldnetpayments.com

+ Google Analytics (Traffic monitoring)

+ Azure Application Insight (Technical monitoring)

17. __Changes to this Privacy Statement__

17.1 This Privacy Policy may be modified from time to time and any such change shall be reflected on the Website or the App with the updated version of the Privacy Policy and Users agree to be bound to any changes to the updated version of Privacy Policy when they use the Website or the App.

17.2 Users acknowledge and agree that it is your responsibility to review the Website or the App and this Privacy Policy periodically and to be aware of any modifications. We will post updates to this Privacy Policy here.

17.3 We reserve the right to correct any errors, inaccuracies or omissions and to change or update the information at any time, without prior notice in case there is any information on the Website or the App that contains typographical errors, inaccuracies or omissions that may relate to service descriptions, pricing, availability and various other information.

18. __Contact us__

18.1 For any questions about this Privacy Policy, please contact us via email at [contact@easyadm.com](mailto:contact@easyadm.com)