Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, Fragment Ltd. (“Fragment” “we”, “our” or “us”) use, collect, disclose, and store Personal Data we collect or receive from or about you (“you”) such as in the following use cases:

1. When you make use of, or interact with, our platform and/or website https://www.fragment.fit/ (“Website”);
   1. When you create an account and sign in
   2. When we process your job application
   3. When you contact us (e.g. customer support, need help, submit a request)
2. When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data 
3. When we use the Personal Data of our customers (e.g. contact details) 
4. When we use the Personal Data of our service providers (e.g. contact details) 
5. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn) 

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. 

Table of contents:  

1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your Personal Data
3. How we share your Personal Data
4. Your privacy rights
5. Use by children
6. Interaction with third party products
7. Log files 
8. Analytic tools
9. Specific provisions applicable under California privacy law
10. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). 

1. HOW WE PROTECT AND RETAIN YOUR INFORMATION 

1. Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

1. Retention of your Personal Data. Until we no longer need the information and proactively delete it, or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws. Please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies. 

1.  HOW WE SHARE YOUR PERSONAL DATA 

We may share your Personal Data as follows:

1. We may also share information with our affiliated companies about you. 
2. We may use third party service providers to process your information for the purposes outlined above, including, without limitation: 
   1. With cloud service providers for hosting purposes;
   2. With websites and web content creation platforms in order to help us manage our Website;
   3. With email providers, marketing, CRM, other similar tool providers; and
   4. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.
3. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Fragment, our services, customers, employees, property, and the public..
4. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.
5. Where you have otherwise provided your consent to us for sharing or transferring your information.

If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to info@fragment.fit.

1. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
   1. You have the right to withdraw consent to the processing, where consent is the basis of processing. 
   2. You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.
   3. You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.
   4. You have the right to object to unlawful data processing under certain conditions.
   5. You have the right to the erasure of past data about you (your “right to be forgotten”) under certain conditions.
   6. You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.
   7. You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
   8. The personal information we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by Titan by contacting Titan directly or by following the instructions through the unsubscribe options in our email messages.
2. You can exercise your rights by contacting us at info@fragment.fit. 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 need further information in order to fulfil 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 requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
3. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to info@fragment.fit. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.
4. Deleting your account: Should you ever decide to delete your account, you may do so by emailing info@fragment.fit. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

1. USE BY CHILDREN 

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@fragment.fit. 

1. INTERACTION WITH THIRD PARTY PRODUCTS 

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

1. LOG FILES 

We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

1. COOKIES AND ANALYTIC TOOLS  

• Cookies. Our Services may utilize “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Services and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Services. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
• Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 
• We reserve the right to remove or add new analytic tools.

1. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

1. California Privacy Rights: 

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please send an email to info@fragment.fit. Please note that we are only required to respond to one request per customer each year.

1. Our California Do Not Track Notice (Shine the Light): 

We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website.

1. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at  info@fragment.fit.

• Data controller: Fragment Ltd.