Last modified: 01 March 2024
This Privacy Policy describes how we – ComBTAS LTD. (together with its affiliates and subsidiaries) responsible for collecting and maintaining certain information collected about you, in regard of the Organization you belong to (“Organization”). This Privacy Policy (“Policy”) applies to our sites, products, and services (collectively,“Services”) that link to this Policy. ComBTAS LTD. is the responsible entity for all Personal Information subject to this Privacy Policy for our Services.
Your privacy is important to us, and we are strongly committed to making our practices regarding your personal data more transparent and fairer. Please read this Privacy Policy carefully and make sure that you fully understand and agree to it.
1. Data Controller/Processor
We are the Data processor of any Personal Data acquired by the Service. Your Organization is the Data Controller of the Personal Data contained in the Service.
ComBTAS LTD. is the “Data Processor” of its provides Services. As such, ComBTAS LTD. process data on the Organization behalf, and does not own the Personal Data or control its use by the Organization. Personal Data will only be processed by ComBTAS LTD. on behalf of our Customer, which is the owner of the respective Account, along with all other User Data processed on such Organization behalf.
Your Organization is the “Data Controller”. Your Organization is responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control). Your Organization will be responsible for establishing appropriate processes and policies to protect access and use to personal data as required. as well as User Data consisting of profile and contact details. With respect to such data, we assume the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy.
2. Data Collection
We collect technical data, profile data, travel data, expense data, and other data received from you, your Organization and your Organization’sthird-party sources.
ComBTAS LTD. collect various types of personal data regarding our Users. Such data is typically received from your Organization, through manual or automated means, or directly from you.
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “Personal Data“):
Collection of general data and information: The Services of ComBTAS LTD collects a series of general data and information when a data subject or automated system calls up the systems. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used,(2) the operating system used by the accessing system, (3) the date and time of access to the Internet site,(4) an Internet protocol address (IP address), (5) the Internet service provider of the accessing system, (6) the cookies and pixels installed or utilized on such device and the recorded activity (sessions, clicks and other interactions),and (7) any other similar data and information that maybe used in the event of attacks on our information technology systems.
When using these general data and information, the ComBTAS LTD does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our systems, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the ComBTAS LTD analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
Data collected by your Organization: Our Services may collect, according to your Organization requirements, either manually or by automated procedures, personal and employee’s data. This data will be used to provide you with the required services of your Organization. Collected may be (1) personal identifications such as name and id’s, (2)contact information such as emails, phone numbers and address information, (3)travel documentation such as passport details, visa, membership clubs and drivers licensed (4) employee’s data such as employee code, title, role, division, position etc., (5) any other data required by your Organization to manage the Service.
Personal data will be used only to provide the required services of the system. This data is controlled by your Organization and will not be used outside the scope of your Organization needs.
User Data received from you: When you use the Service, you may be required or be able to add additional personal, you may provide us with Personal Data. Some of this information maybe mandatory for use of the Service, according to your Organization policy. This includes your name, contact details (such as e-mail, phone, and address),account login details as well as any other data you choose to provide when you use our Service. You may also provide us with your profile photo, location, time-zone, and activity logs and data (collectively, “User Data”).
3. Data Uses
We use Personal Data to provide the required services of our system for your Organization and to comply with applicable laws.
We use Personal Data as necessary for the requirements of our Service; and to comply with our legal and contractual obligations.
If you reside or are using the Service in a territory governed by privacy laws which determine that “consent” is the only or most appropriate legal basis for processing Personal Data (in general, or specifically with respect to the types of Personal Data you choose to share via the Service), your acceptance of this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us by emailat support@tripex.io.
Specifically, we use Personal Data for the following purposes:
- To authenticate the identity of our users, and to allow them to access our service.
- To submit email notifications on processes of the service.
- To submit travel requests to your Organization supplier as permitted by your Organization.
- To create aggregated statistical data, inferred non-personal data or anonymized or data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
- To comply with applicable laws and regulations.
4. Data Location& Retention
We store your data in multiple locations around the world, for as long as necessary in accordance with reasonable business needs and in accordance with our legal obligations.
Data Location: We and our authorized Service Providers (defined below) maintain, store and process Personal Data in the
Europe, Israel, East Asia, and other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required bylaw.
ComBTAS LTD. Ltd. is head quartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents. While privacy laws may vary between jurisdictions, ComBTAS LTD., its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction from which such data originated.
Data Retention: We will retain your Personal Data for as long as it is reasonably necessary in order to maintain and provide you with our Service; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
5. Cookies and Tracking Technologies
We and our Service Providers use cookies and other technologies for session management and personalization purposes.
Our Sites and Service(including some of our Service Providers) utilize “cookies”, and other technologies in order for us to provide our Service and ensure that it performs properly, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device.
6. Data Security
We secure your Personal Data using industry-standard physical, procedural and technical measures.
In order to protect your Personal Data held with us, we are using industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.
7. Data Subject Rights
Individuals have rights concerning their Personal Data. You may exercise your rights by contacting your Account Admin.
If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR), such as the right to request access to, and rectification or erasure of your Personal Data held with ComBTAS LTD., or to restrict or object to such Personal Data’s processing, or to port such Personal Data – please contact your account admin.
8. Additional Information
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Service. The amended version will be effective as of the date it is published. Your continued use of the Service after the changes have been implemented will constitute your acceptance of the changes.
CISO: ComBTAS LTD. has appointed Eyal Levin as our Chief of Information Security Officer, for monitoring and advising on ComBTAS LTD.’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by ComBTAS LTD., you can contact ciso@tripex.io.