Privacy Policy 
RubyComm Ltd

Purpose
The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the following:

 

1. The personal data we will collect;

2. Use of collected data;

3. Who has access to the data collected;

4. The rights of Site users; and

5. The Site's cookie policy
    

This Privacy Policy applies in addition to the terms and conditions of our Site.

PIPEDA (Canada)
For users in Canada, we adhere to the Personal Information Protection and Electronic Documents Act (PIPEDA). As a company engaged in commercial activities that may collect, use, or disclose personal information of Canadians, we are committed to following PIPEDA's 10 fair information principles:

 

• Accountability: We have appointed a Data Protection Officer responsible for PIPEDA compliance

• Identifying purposes: We clearly identify purposes for collecting personal information before or at the time of collection

• Consent: We obtain meaningful consent for collection, use, and disclosure of personal information

• Limiting collection: We collect only personal information necessary for identified purposes

• Limiting use, disclosure, and retention: We use information only for stated purposes and retain it only as long as necessary

• Accuracy: We ensure personal information is accurate, complete, and up-to-date

• Safeguards: We implement appropriate security measures to protect personal information

• Openness: We make our privacy policies and practices readily available

• Individual access: We provide individuals access to their personal information upon request

• Challenging compliance: We maintain procedures for addressing privacy complaints

GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

Israeli Privacy Protection Law
For users in Israel and processing of personal data within Israel, we adhere to the Israeli Privacy Protection Law (התשמ"א-1981) and the Information Security Regulations (התשע"ז-2017). As an Israeli company, we are committed to protecting your personal information in accordance with Israeli privacy legislation and maintaining appropriate security measures as required by Israeli law.

US State Privacy Laws and International Privacy Rights
For users in US states with applicable privacy laws (including California, Virginia, Colorado, Connecticut, Utah, Texas, Florida, and others), we comply with relevant state privacy requirements where they apply to our operations.
For users in other jurisdictions with applicable privacy laws, we strive to comply with relevant international privacy requirements. US residents and international users may have rights including access to personal information, correction of inaccurate data, deletion of personal information, and opting out of certain data processing activities, subject to applicable law thresholds and exemptions.
If you believe you have rights under applicable privacy laws and would like to exercise them, please contact our Data Protection Officer at dpo@rubycomm.com. We will respond to your request in accordance with applicable law requirements and timelines.

Consent
By using our Site users agree that they consent to:

• The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.
You can withdraw your consent by contacting the RubyComm Data Protection Officer at dpo@rubycomm.com

Legal Basis for Processing

For Canadian users: We collect and process personal information in accordance with PIPEDA's fair information principles and only for purposes that a reasonable person would consider appropriate in the circumstances.
 

For EU users: We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

For Israeli users: We collect and process personal data in accordance with the Israeli Privacy Protection Law and only for legitimate purposes as defined by Israeli privacy legislation.
We rely on the following legal bases to collect and process personal data:

• Users have provided their consent to the processing of their data for specific purposes

• Processing is necessary for the performance of a contract or taking steps before entering a contract. If a user does not provide the personal data necessary to perform a contract, a mutual commercial agreement may become null and void

• Processing is necessary for compliance with legal obligations

• Processing is necessary for legitimate interests pursued by us or third parties

Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically
When you visit and use our Site, we may automatically collect and store the following information:

 

• IP address (which may be considered personal information under PIPEDA when combined with other automatically collected data)

• Country

• Hardware and software details

• Clicked links

• Content viewed
   

Note for Canadian users: IP addresses are considered personal information under PIPEDA, particularly when combined with other automatically collected data. We collect IP addresses for essential website functionality, security monitoring, and analytics purposes.

How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.
The data we collect automatically is used for the following purposes:
 

• Essential website functionality: Enabling proper website operation and user experience

• Security monitoring: Detecting and preventing unauthorized access or cyber attacks

• Statistical analysis: Understanding website usage patterns to improve our services

Who We Share Personal Data With

Employees
We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Third Parties
We may share user data with the following third parties:

• Google Analytics

We may share the following user data with third parties:

• Information such as sessions/visitors by traffic source/category, sessions by device and sessions by country

We may share user data with third parties for the following purposes:

• Traffic analysis for website optimization

Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.

Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:

 

• If the law requires it

• If it is required for any legal proceeding

• To prove or protect our legal rights

• To buyers or potential buyers of this company in the event that we seek to sell the company

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.

How We Protect Your Personal Data
RubyComm Ltd is ISO 27001:2022 certified and protects its data and information systems accordingly.
While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

Your Rights as a User

Under PIPEDA (for Canadian users), you have the following rights:

• Right to access: You have the right to request information about the personal information we hold about you, including how it's used and to whom it's disclosed

• Right to correction: You have the right to request correction of inaccurate personal information

• Right to withdraw consent: You can withdraw your consent for the processing of your personal information at any time

• Right to challenge compliance: You have the right to challenge our compliance with PIPEDA's fair information principles
   

Under the GDPR (for EU users), you have the following rights:

• Right to be informed

• Right of access

• Right to rectification

• Right to erasure

• Right to restrict processing

• Right to data portability

• Right to object

Under Israeli Privacy Protection Law (for Israeli users), you have the following rights:

• Right to access your personal information held by us

• Right to correct inaccurate personal information

• Right to request deletion of personal information in certain circumstances

• Right to object to processing in certain cases

Data Breach Notification

For Canadian users: In accordance with PIPEDA's mandatory breach notification requirements, we will notify the Office of the Privacy Commissioner of Canada and affected individuals of any breach of security safeguards involving personal information that creates a real risk of significant harm to individuals.

Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our data protection officer.

How to Access, Modify, Delete, or Challenge the Data Collected

For Canadian users under PIPEDA: You have the right to access your personal information held by us. We will respond to written requests within 30 days and provide information at minimal or no cost.
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to whom we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under PIPEDA, GDPR, or Israeli Privacy Law, please contact our data protection officer at:
dpo@rubycomm.com

How to Opt-Out of Data Collection, Use or Disclosure
In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:
Marketing cookies, functional cookies and analytics cookies. You can opt-out by adjusting the Advanced Cookie Settings menu.

Cookie Policy
A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.
We use the following types of cookies on our Site:

​

• Functional cookies: Used to remember the selections you make on our Site so that your selections are saved for your next visits

• Analytical cookies: Allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc.

• Marketing Cookies: To track advertising effectiveness

• Third-Party Cookies: Created by a website other than ours

Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Last Updated" date at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

Complaints
If you have any complaints about how we process your personal data, you may submit a complaint directly through our Privacy Complaints Form (under the website legal section) or contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue.

We will acknowledge receipt of your complaint and aim to respond within 30 days.

If you feel we have not addressed your concern in a satisfactory manner:

Canadian users: may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or through their website at www.priv.gc.ca
EU users: may contact a supervisory authority
Israeli users: may contact the Israeli Privacy Protection Authority
US users: may contact relevant state attorney general offices or consumer protection agencies in states with applicable privacy laws
UK users: may contact the Information Commissioner's Office

Contact Information

Data Protection Officer: dpo@rubycomm.com
Privacy Complaints: Use our online Privacy Complaints Form (under the website legal section)  or email dpo@rubycomm.com

Office of the Privacy Commissioner of Canada (for Canadian users):

• Address: 30 Victoria Street, Gatineau, Quebec K1A 1H3

• Phone: 1-800-282-1376 (toll-free) or 819-994-5444

• Website: www.priv.gc.ca
  
  If you have any questions, concerns or complaints, you can contact our data protection officer at: dpo@rubycomm.com