Privacy & Cookie Policy

Organogram LTD (“Organogram”, “Company”, “we”, “us” or “our”) offers an online cloud automation platform (“ERP”) for enterprises and other organizations. This Privacy and Cookie Policy (“Privacy Policy”) describes how we collect, use, store, share, and protect personal data from Website Visitors, Customers, and/or Vendors (“Data Subjects”) who engage with our services. It applies to our website and all related applications, mobile apps, web apps, command line apps and other tools (collectively, our “Services”).

Our Services are primarily intended for and provided to businesses and other organizations (“Organizations”), and not individual consumers. Thus, we generally process personal data at the direction of and on behalf of Organizations. When we do, we do so as a service provider or a “Data Processor” to these Organizations. We also provide integration on behalf of Organizations, who choose to use other services provided by 3rd-party companies (“3rd Parties”) when authorized by Organizations. In all these instances, we do not control and are not responsible for the privacy practices of those Organizations and 3rd Parties.

This Privacy Policy does not apply to services that are not owned or controlled by Organogram, including third-party websites and the services of 3rd Parties. This Privacy Policy applies to all forms of systems, operations and processes within the Organogram environment that involve the processing of personal data.

By using or accessing our Services, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. Your use of our Services is also subject to Organogram’s Terms.

• The Information we Collect

The personal data we collect depends on how you interact with us, the services you use, and the choices you make. We may collect information from different sources and in various ways, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.

1.1 Personal Data You Provide Directly
We collect personal data you provide to us. For example:

Contact information. As part of our operations, Organogram may collect information such as your name, telephone numbers, address etc and that of individuals in your organization.

Integration and Payment information. If you make payments or purchases such as when you make payments with Organogram on a Partner’s website, we may collect financial account information, and other payment details.

Communications. If you contact us directly, for example, with an inquiry or a support request, we may receive additional personal data about you, including the content of your communications.

1.2 Personal Data We Collect Automatically

Device Information. We receive information about the device and software you use to access our Services, including Internet Protocol (IP) address, web browser type, operating system version, and device identifiers.

Usage Information. To help us understand how you use our Services, including the Demo portion of our website, and to help us improve them, we automatically receive information about your interactions with our Services. This information includes records of your transactions and information about your other activities related to our services, such as date and time of your sessions, the pages you view, links to/from any page, and time spent in a session. Some of the data we gather through the use of cookies and similar technologies as discussed below.

Location Information. When you use our Services, we may collect or infer your general location information. For example, your IP address may indicate your general geographic region.




1.3 Personal Data That We Receive or Infer from Others
Partners. We may retrieve additional personal data about you from third parties and other identification/verification services such as your financial institution and payment processor. We may combine that data with other information we have about you.

Publicly available sources. Public sources of information such as open government databases.

Inferences. We may infer additional Personal Data based on the Personal Data described above. For example, for site visitors, we may infer your interests based on the web pages you view. When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.



• How We Use Personal Information

We use the Personal Data we collect to:

• Provide you with the required services
• Respond to your questions or requests
• Improve features, website content and analyse data to develop products and services
• Address inappropriate use of our website
• Prevent, detect and manage risk against fraud and illegal activities using internal and third party screening tools
• Send you marketing content, newsletters and service updates curated by Organogram but only with your explicit consent
• Verify your identity and the information you provide in line with Organogram’s statutory obligations using internal and third party tools
• Maintain up-to-date records
• Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies
• Any other purpose that we disclose to you in the course of providing Organogram services to you
• How We Share Personal Data

Organogram does not sell, trade or rent personal data to anyone. Further, we will not share or disclose your personal data with a third party without your consent except as necessary to provide the Services or as described in this Privacy Policy.

Partners. We may share your contact information with Partners as part of your integration requirements and purchases and for record purposes. We will not share this information with other third parties except as a necessary part of providing our website and services.

Service providers. We share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to provide customer service support, to assist in protecting and securing our systems and services, or to perform sanctions screening and identity verification services may need access to personal data to provide those functions. The processing by such third parties shall be governed by a written contract with Organogram to ensure adequate protection and security measures are put in place for the protection of personal data in accordance with the terms of this Privacy Policy.

Financial services & payment processing. When you provide payment data, for example to make a purchase, we will share payment and transactional data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.

Affiliates. We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access is needed to provide our services and operate our business.

Corporate transactions. We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

Legal and law enforcement. We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.

Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to:

• protect our customers and others, for example to prevent fraud, or to help prevent the loss of life or serious injury of anyone;
• operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
• protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.

Third party analytics and advertising companies also collect personal data through our website and apps including, account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the Cookies section of this statement. These third party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.
Finally, we may use or share anonymized information in accordance with applicable law.
Please note that partners, 3rd parties, sellers, and other users you buy from or contract with have their own respective privacy policies, and although Organogram’s Partner Terms of Use does not allow the other transacting party to use your information for anything other than as authorized by you, Organogram is not responsible for their actions, including their data protection practices. If you provide personal data to any of those third parties, or allow us to share personal data with them, that data is governed by their privacy policies.