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* CCPA Gizlilik Bildirimi
# **CCPA Gizlilik Bildirimi**
#### **A. INTRODUCTION**
This **CCPA** **Privacy Notice** governs the manner in which Ongage processes information collected from consumers who reside in the State of California (“**Consumers**” as defined under the California Consumer Privacy Act of 2018 (“**CCPA**“), and will be referred herein as “**you**”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. Further, this Privacy Notice is an integral part of our Privacy Policy and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our .
To learn more about your California privacy rights, please visit: 
#### **B. CATEGORIES OF PERSONAL INFORMATION**
When you use the Site and Services, we collect certain data regarding such use. This data includes “**Personal Information**” that is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device as detailed in the table below.
***Please see below a list detailing the categories of Personal Information that we collect (and have collected within the last 12 months):***
* **CATEGORY A – Identifiers (Collected):**A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
* **CATEGORY B – Personal information categories listed in the California Customer Records statute [Cal. Civ. Code § 1798.80(e)] (Collected):**A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
* **CATEGORY C – Protected classification characteristics under California or federal law (Collected):**Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
* **CATEGORY D – Commercial information (Not Collected):**Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
* **CATEGORY E – Biometric Information (Not Collected):**Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
* **CATEGORY F – Internet or other similar network activity (Collected):**Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
* **CATEGORY G – Geolocation data (Collected):**Physical location or movements.
* **CATEGORY H – Sensory data (Not Collected):**Audio, electronic, visual, thermal, olfactory, or similar information.
* **CATEGORY I – Professional or employment-related information (Not Collected):**Current or past job history or performance evaluations.
* **CATEGORY J – Non-public education information, per the Family Educational Rights and Privacy Act [20 U.S.C. Section 1232g, 34 C.F.R. Part 99] (Not Collected):**Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
* **CATEGORY K – Inferences drawn from other personal information (Not Collected):**Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
#### **C. DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE**
In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:
* Category A: Identifiers;
* Category B: Personal information categories listed in the California Customer Records statute [Cal. Civ. Code § 1798.80(e)];
* Category C: Protected classification characteristics under California or federal law;
* Category F: Internet or other similar network activity.
We disclose your Personal Information for a business purpose to the following categories of third parties: service providers, business partners, government agencies, etc.
When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
#### **D. HOW WE COLLECT INFORMATION**
We collect the above data from you, in the following ways:
(i)  In the event you voluntarily choose to provide us with information, e.g., when you contact us.
(ii)  Automatically when you are using our Services embedded in our Customer’s websites, including through the use of cookies (as detailed in our ), and other similar tracking technologies.
#### **E. USE OF PERSONAL INFORMATION**
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
* To fulfill or meet the reason you provided the information. For example, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry.
* To improve our Services.
* For security and fraud detection purposes, and to maintain the safety, security, and integrity of our Services.
* To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
* As described to you when collecting your Personal Information or as otherwise set forth in the Privacy Policy
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
#### **F. SALE OF PERSONAL INFORMATION**
In the preceding twelve (12) months, we have not sold Personal Information.
#### **G. USERS’ RIGHTS & CONTROLS**
The CCPA provides consumers with specific rights regarding their Personal Information. Please review our  regarding your rights under applicable law.
We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information, depending on your relationship with us. You may exercise any or all of your above rights in relation to your Personal Information by contacting our customer support at: **csr@gclexperts.com**
#### **H. AMENDMENTS**
As required under the CCPA, we will **update** this Privacy Notice **every 12 months**. The last revision date will be reflected in the “Last Modified” heading located at the bottom of the .
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Bize Ulaşın:
Tel (USA): +1-917-444-9402
csr@gclexperts.com
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* Güvenlik Politikası
# **Güvenlik Politikası**
**[Last updated on April 1, 2021]**
**Post Haste S.L.** (“**Company**” or “**we**” or **“our”**) is committed to provide transparency regarding the security measures and policies which it has implemented in order to secure and protect personal data and personal identifying information (together “**Personal Data**“), all as defined under applicable data protection law, including without limitations, the EU General Data Protection Regulation (“**GDPR**”).
This information security policy (“**Security** **Policy**”) outlines the Company’s current security measures deployed by the Company as of the “Last Updated” date indicated above. We will keep updating this Security Policy from time to time, as required by applicable laws and our internal policies**.**
The Company has implemented technical and organizational safeguards, and established a comprehensive information and cyber security program, all for the purpose of protecting the Personal Data processed by the Company.
### **Physical Access Control**
We ensure the protection against the unwanted and unauthorized physical access to our servers and facilities that store the Personal Data. We have chosen the reputable Microsoft Azure as our cloud storage provider. The Personal Data collected by the Company is stored in the Azure data servers. For more information regarding the data security provided by Microsoft Azure, please see: **<
Further, the Company secures the physical access to its offices using a passcode to ensure that solely authorized individuals such as employees and authorized external parties (maintenance staff, visitors, etc.) can access the Company’s offices. The Company’s offices include fire and smoke alarms in place. All data backups are stored in data safes protected from fire and water.
### **Security Risk Analysis and Management**
The Company conducts an accurate and thorough assessment of the potential risks and vulnerabilities of the Company’s Personal Data to ensure the confidentiality, integrity, and availability of electronic protected Personal Data. The Company applies a periodic testing of the Company’s disaster plan in order to ensure that the Company can cope with a consummation of any disaster and emergency case. Our servers include an automated back-up procedure. As mentioned above, the Company’s office is equipped with fire detectors, fire extinguishers and other applicable measures for the case of consummation of a natural disaster.
### **System Control**
The access to the Company’s database is highly restricted in order to ensure that solely the appropriate prior approved personnel can access the Company’s Personal Data. Safeguards related to remote access and wireless computing capabilities are implemented therein. Employees are required to comply with the Company’s password policy when composing a password in order to allow strict access or use related to Personal Data all in accordance with position, and solely to the extent such access or use is required.
There is constant monitoring of the access to the data and the passwords used to gain login access. In addition, the Company implements an automatic captcha, lock-out mechanism, and disables any saving password program in order to prevent any unauthorized login to the Company’s servers by the means of password guessing. Electronic procedures in order to terminate an inactive session are also in use by the Company.
### **Data Access Control**
There are restrictions in place to ensure that access to the Personal Data is restricted to employees who have permission to access it. Any permission is granted by the Company’s cyber security officer. The Personal Data information shall not be accessed, modified, copied, used, transferred or deleted without specific authorization. Access to the Personal Data information, as well as any action performed involving the use of the Personal Data, requires a user name and password, which is routinely changed, as well as blocked when applicable. The user password is fully encrypted. Each employee is able to perform actions solely according to the permissions determined by the Company. Each access is logged and monitored, and any unauthorized access is automatically reported.
### **Removable Media and Media Controls**
Any use of an electronic removable media shall be done according to the Company’s removable media policy to prevent loss of any Personal Data. The disposition of any removable media is done according to the Company’s removable media disposition policy. The Company’s employees may remotely access the Personal Data according to the Company’s policy. The remote control by the employees is subject to the usage of specific remote-control software which keeps the connection secure and encrypted.
### **Organizational and Operational Security**
The Company invests a multitude of efforts and resources in order to ensure compliance with the Company’s security practices, as well as continuously provides employees on-going training and periodic updates regarding the Company’s security procedures. The Company strives to raise awareness to the risk involved in the processing of Personal Data. In addition, the Company has implemented applicable safeguards for its hardware and software, including web content filtering, firewalls and anti-virus software (“**Protection Measures**”) on applicable Company hardware, software or employee’s computer, in order to protect against viruses, worms, Trojan identifications or any other malicious software. The Protection Measures cannot be deactivated by any user other than the Company’s cyber security officer and according to the Company’s policies.
### **Transfer Control**
All transfer of Personal Data between the client side and the Company’s servers is protected using encryption safeguards, as well as encryption of the Personal Data prior to the transfer of any Personal Data. The Company’s servers are protected by industry best standards. Furthermore, the destruction of Personal Data following termination of the engagement is included within the contract between the parties. In addition, to the extent applicable, the Company’s business partners execute an applicable Data Processing Agreement, all in accordance with applicable laws.
### **Data Retention**
Personal Data is retained for as long as needed to provide the services or as required under applicable laws. Individuals may request data deletion; however, this request is not absolute and is limited, all as detailed in the Company 
### **Job Control**
All of the Company’s employees are required to execute an employment agreement which includes confidentiality provisions as well as applicable data protection provisions binding them to comply with the Company’s policies, in particular, the computer security policy. In addition, employees undergo a screening process applicable per regional law. In the event of a breach of an employee’s obligation or non-compliance with the Company’s policies, the Company includes repercussions to ensure compliance with the policies all according to the Company’s sanction policy. In addition, prior to the Company’s engagement with third party contractors, the Company reviews such third party’s security policies, specifically their information data security policies, to ensure it complies with the Company’s standard for data security protection. Third party contractors may solely access the Personal Data as explicitly instructed by the Company.