Privacy Policy

  1. Introduction

ActiveTrail Ltd. (hereinafter: “the Company” or “ActiveTrail” or “Us” or “Our”) provides businesses and organizations with a wide range of tools and products to independently create, operate and manage Customer journeys across several channels, including, but not limited to, email, SMS, WhatsApp, mobile push, surveys, landing pages, automation, and more.

ActiveTrail is committed to protecting Your privacy. To protect Your personal information, we constantly invest in advanced security measures and follow industry standards and best practices. Our commitment to data privacy is based on transparency, appropriate data management, and a strong emphasis on trust.

Please read this Privacy and Cookie Notice carefully, so You can fully understand Our practices in relation to the collection, use, process, storing, and protection of Your personal data.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy and Cookie Notice.

Please Note: YOU ARE NOT OBLIGATED TO PROVIDE US WITH ANY PERSONAL DATA. YOU HEREBY ACKNOWLEDGE AND AGREE THAT YOU ARE PROVIDING US WITH SUCH INFORMATION OF YOUR OWN FREE WILL, FOR THE PURPOSES DESCRIBED IN THIS DOCUMENT AND THAT WE MAY RETAIN SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS DOCUMENT AND ANY APPLICABLE LAWS AND REGULATIONS.

  1. Definitions/Interpretations

The words of which the initial letter is capitalized have meanings defined under the following conditions.

In this Privacy Policy, these words refer to or means as follows:

  • Company” – referred to ActiveTrail Ltd. as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy. For the purpose of the GDPR, the Company is considered a Data Controller regarding the User and Visitor’s Personal Data, and a Processor regarding the User’s Contact Data
  • GDPR“- EU 2016/679 General Data Protection Regulation.
  • Personal Data” is any information that relates to an identified or identifiable individual.
  • “Identifiable Individual” is one who can be identified, directly or indirectly, in particular by reference to an identifier.
  • User” – an individual/entity who is a paying or trial customer of ActiveTrail and/or that uses the Company’s systems and thus has an established relationship with ActiveTrail.
  • “Visitor” – an individual/entity that visits our website (activetrail.com/es/de/fr or any other website owned and managed by ActiveTrail).
  • Contact” – shall refer to any individual appearing on a User’s mailing list and/or database held by a User on Our systems.
  • You” and “your” – depending on the context, either a User, a Contact, or a Visitor.
  • Service“- refers to the Website and all services offered by Us via the website, as well as Our
  • Website“- refers to Activetrail.com, accessible from https://www.activetrail.com/ and all ActiveTrail websites on different domains. (activetrail.com/es/de/fr or any other website owned and managed by ActiveTrail).
  • Account“- a unique and secure user profile created within Our platform, enabling the User to access certain features, functionalities, or content.
  • Cookies“- Small text files stored on Your device by a web browser when visiting a website or using an application. Cookies are used to remember Your preferences, enhance website functionality, and enable personalized content delivery. They may contain information such as login details, browsing history, and specific settings. (For more info, please read our Cookies Policy)
  • Usage Data” refers to a subset of non-personally identifiable information automatically collected from You when You interact with our website, application, or service. usage data may include but is not limited to, browser type, operating system, device information, IP address, access times, pages viewed, and Your interactions.
  • Device“- means physical electronic equipment used by You to access, interact with, or engage with our service. Examples of devices include but are not limited to, desktop computers, laptops, tablets, smartphones, and smartwatches.
  • Service Provider“- means a third-party company or individual that provides specific services or solutions to the Company, often in relation to the processing of personal data or the delivery of certain features and functionalities within Our website, application, or service. Service providers may include, but are not limited to, web hosting providers, payment processors, and analytics companies. For the purpose of the GDPR, Service Providers are considered Data Processors regarding the User and Visitor Personal Data, and a Sub-Processor regarding the Contact Data.
  • Data Processor“- An entity that processes personal data on behalf of the data controller, often a third-party service provider engaged by the controller. For the purpose of the GDPR, the Company acts as a data processor regarding the “Contact” data.
  • Data Processing“- Any operation or set of operations performed on personal data, including collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, or erasure.
  • Data Controller“- for the purposes of the GDPR, refers to the Company as the legal body, which alone or jointly with others determines the purposes and means of the processing of Personal Data. ActiveTrail Ltd is the data controller responsible for the processing of the User and Visitor Data, exceptions are outlined in this Privacy and Cookies Notice.

Our designated privacy representative in the EU can be reached at the following address:

Caroline Quercy

Address:

119 rue du Président Wilson

92300 Levallois-Perret

France

Email: Caroline@activetrail.eu

  1. Data Protection Officer

The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following email address: dpo@activetrail.net

  1. Types of Data Collected

User Personal Data

While using Our Service, We may request personally identifiable information from You that can be used to contact or identify You. This data may include, but is not limited to:

  • Your Professional Email address
  • First name and last name of the Company’s representative [Point of Contact]
  • Job title of the Point of Contact
  • Company’s Name, Address, State/country, ZIP/Postal code, City
  • Point of Contact and Company’s Contact details
  • Company’s billing information.
  • Account Username and activity.
  • The type of Service we provide you with
  • any other Personal Data that you decide to provide/supply us with

Visitor Personal Data

While visiting Our website, We may collect Usage data as defined below and if you choose to contact us, we may request personally identifiable information from You that can be used to contact or respond to Your Inquiry. This data may include, but is not limited to:

  • First name and last name
  • Your Email
  • Your Phone Number
  • Website
  • The type of support Your seeking [Sales, Marketing, Other]
  • How did you hear about ActiveTrail
  • Your inquiry content and any other Personal Data You share with Us.

Usage Data – Relevant for Users and Visitors

Usage Data is collected automatically when using the Service as a User and a Visitor.

Usage Data may include information such as browser type, operating system, device information, IP address, access times, pages viewed, and Your interactions with the platform. This data is primarily used for analytics purposes, improving platform performance, and enhancing the overall user experience, in accordance with our Privacy and Cookie Notice.

When You access the Service via a mobile device, We may automatically collect certain information, including but not limited to the type of mobile device You are using, Your mobile device’s unique ID, Your mobile device’s IP address, Your mobile operating system, the type of mobile Internet browser, unique device identifiers, and other diagnostic data. We may also collect information that your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

For more information about the cookies we use, and your choices regarding cookies, please visit our Cookies Policy.

Contact Personal Data
The Company acts as a Processor for Your Information. Your data is provided by Our User and Your email address appears on our User’s mailing lists and/or databases stored on our systems, you may receive emails sent to you by our Users using our systems. Thus, Our User is the Data Controller of your Data and Your Consent is provided to Our User.

  1. How we collect your data

We want to inform you about the various methods we use to collect data when you interact with our Services as part of our commitment to protecting your privacy. The primary methods we use are as follows:

Users and Visitors

  • Direct Collection: We obtain personal data directly from you when you voluntarily provide it to us, such as when you create an account or contact us via the website channel or via mail.
  • Automated Collection: As you interact with our service, certain usage data and technical information may be automatically collected through cookies, server logs, and other tracking technologies. This may include, among other things, details about your device, browser, IP address, access times, and pages viewed.

Contacts

  • Indirect Collection: We obtain Your Data through Our Users who choose to purchase services from the Company and are legally bound via a contractual framework with Us.

Please keep in mind that our Privacy and Cookie Notice explains how we use and protect the data collected through these methods and the options and rights you have regarding your data.

  1. Purpose of Data Processing and Use of Your Personal Data

We may use Personal Data for the following purposes:

  • To provide you with the requested services: We use Your Personal Data to respond to Your requests, such as providing customer service, and delivering Our services to You.
  • To improve, support, and analyze Our services: We may use Your Personal Data to conduct research and analysis to improve Our services. This includes gathering feedback on Our services, analyzing website traffic and usage patterns, and identifying areas for improvement.
  • To Manage Your Account- Users: to manage Your registration as a user of the Service. The Personal Data You provide can give you access to different functionalities of the Service that are available to You as a registered user such as providing Our products and services.
  • To communicate with You: We may use Your personal data to communicate with you about Our services, including marketing communications and promotional offers. If you have opted in to receive marketing communications from us, you can always opt out by following the instructions provided in the communication.
  • To manage Your requests: To attend to and manage Your requests to Us as well as provide an answer and further information to the extent requested.
  • To comply with legal obligations: We may use Your personal data to comply with applicable laws, regulations, and other legal requirements, including responding to lawful requests from law enforcement agencies and government authorities.
  • For other legitimate business purposes: We may use Your personal data for other legitimate business purposes, such as enforcing our terms of service, protecting Our rights and interests, and preventing fraud or other illegal activities.
  1. Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

  1. Share and Disclose Your Personal Data
  • With Service Providers: We also disclose information, including Personal Data we collect from and/or about You, to our trusted third-party service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide You with the Services; (2) aid in their understanding of how users are using our services; Our service providers act as a Processor for User and Visitor Data and as a Sub-Processor for Contact Data. A list of the relevant service providers to your data can be obtained by requesting it from our DPO at: dpo@activetrail.net.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.
  • Business Transactions: If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
  • Law enforcement: Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
  • Other legal requirements: The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting Our DPO at dpo@activetrail.net

  1. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices in Israel and will be maintained, processed, and stored on our private server farm and cloud services located within the EU. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement and consent to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information, as follows:

  • Internal transfers: Transfers within the ActiveTrail Group/Branches/Resellers will be covered by an internal processing agreement entered by members of the ActiveTrail Group/Branches/Resellers (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred to.
  • External transfers: Where we transfer your Personal Data outside of the EU/EEA (for example to third parties who provide us with services), we will obtain relevant contractual framework commitments from them to protect your Personal Data, such as Standard Contractual Clauses (SCC) or Data Transfer Agreement (DTA) /Data Processing Addendum (DPA) depending on which country receiving the data.
  1. Retention of Your Personal Data

The Company will only keep Your Personal Data for as long as it is required for the purposes outlined in this Privacy Policy. We will retain and use Your Personal Data only to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable taxing or accounting laws), resolve disputes, and enforce our legal agreements and policies. We have an internal data retention policy in place to ensure that we do not keep your Personal Data indefinitely. More information about cookie retention can be found in our cookie notice.

Usage Data will also be retained by the Company for internal analysis. Usage Data is typically retained for a shorter period of time, unless it is used to strengthen the security or functionality of Our Service, or We are legally required to retain this data for a longer period of time.

  1. Security of Your Personal Data

We value the security of Your Personal Data and have installed and maintained suitable technical, organizational, and security safeguards to protect it. We use secure servers, firewalls, antivirus, and SSL encryption to protect your Personal Data.

We keep our policies and procedures up to date and evaluate them on a regular basis. We also restrict access to your personal data to employees, agents, contractors, and third parties with a business need to know. They will only process your personal data on our instructions, and they are under the responsibility of confidentiality.

However, keep in mind that no method of Internet transmission or computer storage is 100% safe. We make every effort to protect Your Personal Data using commercially reasonable procedures, but we cannot guarantee total security. Because information security is based in part on the security of the computer, device, or network via which you communicate with Us, as well as the security you use to protect Your IDs and passwords, please take the necessary precautions to protect this Data. If You are concerned about particular personal information, You may desire to avoid passing it over the Internet.

  1. Your rights- Users and Visitors:
    You have the right under this Privacy Policy, by law, and for the purpose of the GDPR, as follows:
  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request the deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • The right to request the erasure and deletion of Personal Data. You have the right to request the erasure deletion of Your Personal Data when there is no good reason for Us to continue processing it. Such erasure is subject to certain exceptions under the GDPR, In the event that one of the exceptions applies, we will notify you in accordance with the law.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request the transfer of Your Personal Data (Data Portability). We will provide to You, or to a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent to use your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
  • You have a right to lodge a complaint with your local data protection supervisory authority: (i.e., your place of habitual residence, place of work, or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

In order to exercise your rights as mentioned above, please contact us at dpo@activetrail.net

Processing and answering your request are Subject to legal and other permissible considerations, we will make every reasonable effort to honor Your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing Your request, we may ask You for additional information to confirm or verify Your identity and for security purposes before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. In the event that Your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with Your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

  1. Your Rights- Contacts

Under applicable law and specifically the GDPR, You have several rights to be practiced regarding your personal data, and We-the Data Processor shall comply with the GDPR and do our best to assist the Data Controller-the User in fulfilling your request for practicing your rights, under legal obligations and restrictions. For any request for practicing your rights regarding personal data processed via our services on behalf of the User, please contact the User whom you consented to be added to their list.  For the purpose of brief acknowledgment, your rights under the GDPR are as follows:

  • The right to be informed.
  • The right to access your Data.
  • The right to rectification of your Data.
  • The right to erasure, “right to be forgotten.”
  • The right to restrict processing.
  • The right to data portability.
  • The right to object to the processing of your personal data.
  • The right not to be subject to automated decision-making.
  • You have a right to lodge a complaint with your local data protection supervisory authority.
  1. Children’s Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

If you believe that we might have any such information, please contact us at dpo@activetrail.net

  1. Interaction with third-party Links

Our Website may contain third-party links, allowing you to engage with third-party websites or services not owned or controlled by us (each a “Third Party Service”). As a result, if You click on a third-party link, You may be sent to that third party’s site, which is not  maintained by Us, and We cannot be held responsible for the privacy practices or content of such Third-Party Services. We encourage you to review the Privacy Policies of every website you visit.

We have no control over and claim no responsibility for, the content, privacy policies, or practices of third-party websites or services.

  1. Cookie Policy

Like many websites and applications, We use “Cookies” and similar technologies for several reasons, to collect information including to help personalize your experience and we also use a cookies tool on our platform to gain consent for the optional cookies we use. Third parties through which we provide the services may be placing and reading cookies on your browser. When visiting our Website, you shall be notified of the use of and placement of cookies and other similar technologies on your device as specified herein.

There are different types of cookies, as follows:

A “session cookie” is temporary and will remain on your device until you leave the Site/platform/service.

A “persistent cookie” may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.

First-party cookies” are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.

We may use the term “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.

For more information on Cookies please visit Our Cookies Customization tool  on our website.

  1. How do we use cookies?

We use cookies and similar technologies for a number of reasons, as specified below. The specific names and types of cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally are Necessary Cookies. These cookies are necessary to allow the Site to work correctly. They enable you to access the Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.

Cookies for better Functionality. These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) to help us personalize your experience and offer you enhanced functionality and content

Analytics and Performance Cookies. These cookies collect information regarding your activity on our platform to help us learn more about which features are popular with our users and how our platform and/or our online services can be improved. It can also help us understand how you use our platform, for example, whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our platform and/or our online services.

Advertising Cookies. These cookies are placed in order to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites. Such cookies may track your browsing habits and activity when visiting our platform and/or our online services and those of third parties.

How to adjust your preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. We provide you with customization cookies tool at our website.

Email Cookies. Additionally, cookies and pixels may be placed in messages we send to track your interaction with such emails.

  1. Contact us

If you have any comments or questions regarding this Privacy Policy, please contact us at : dpo@activetrail.net