This Privacy Policy describes how Tonkean Inc., and its affiliated companies (“Tonkean“, “we“, “our” or “us”) , collects, stores, uses and discloses the following categories of personal data:
Specifically, this Privacy Policy describes our practices regarding:
If you are a Customer, User or Prospect, please read this Privacy Policy carefully and make sure that you fully understand it.
Our Services are designed for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Policy, including information about any visitors to our Sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. However, please keep in mind that without it, we may not be able to provide you with the full range of our Services or deliver the best user experience when interacting with them. If you prefer not to share your personal data, or have it processed by us or any of our Service Providers (as defined below), please refrain from providing your data, visiting or interacting with us or with our Sites, or using our Services. You may also submit a request to exercise your rights as explained in Section 9 below.
1. Data Collection
When we use the term “personal data” or “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Sometimes we collect personal data automatically when an individual interacts with our Services and sometimes we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as our Customers and Service Providers), even before our first direct interaction. Specifically, we collect the following types of personal data:
For the purposes of the California Consumer Privacy Act ("CCPA"), in the last 12 months, we have collected the following categories of Personal Information: Identifiers, Customer Records Information, Internet or other Electronic Network Activity Information, Geolocation Data, Commercial Information; Inferences from Personal Information Collected; and Professional or Employment-Related Information. We do not use or disclose sensitive personal information as defined in the CCPA.
We have collected such Personal Information from the following sources:
2. Data Uses
We use personal data for the purposes and in reliance on the lawful bases described below:
| Purpose | Lawful bases |
|---|---|
| User personal data | |
| To authenticate your identity and provide you access and use of our Services | Performance of Contract (to the extent applicable); Legitimate Interest |
| To facilitate, operate, enhance and provide our Services | Performance of Contract (to the extent applicable); Legitimate Interest |
| To provide assistance and support, to test and monitor the Services, or diagnose or fix technology problems, and train our Customers’ staff on how to use the Services | Performance of Contract (to the extent applicable); Legitimate Interest |
| To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities | Performance of Contract (to the extent applicable); Legitimate Interest |
| User and Prospect personal data | |
| To facilitate and optimize our marketing campaigns, ad management, and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services and thereby increase your engagement and overall satisfaction with our Services | Legitimate Interest; Consent (where applicable) |
| To facilitate, sponsor and offer certain events, contests, and promotions | Legitimate Interest |
| To gain a better understanding of how individuals use and interact with our Services, which content and data they have processed through our Services, and how we can improve their and others’ user experience and the value they can generate from using the Services, so we can continue improving our products, offerings and the overall performance of our Services | Legitimate Interest |
| To contact our Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them | Performance of Contract (to the extent applicable); Legitimate Interest; Consent (where applicable) |
| To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error, or any illegal, criminal or prohibited activity | Performance of Contract (to the extent applicable); Legitimate Interest; Legal Obligation |
| To evaluate, test and monitor our Services, diagnose or fix problems and bugs, as well as develop new features, technologies, and improvements to our Services | Legitimate Interest |
| To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which our business partners or we may use to provide and improve our respective Services, or for any other purpose | Legitimate Interest |
| To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties | Legitimate Interest; Legal Obligation |
| To comply with court orders and warrants, prevent misuse of the Services, and take any action in any related legal dispute and proceeding | Legitimate Interest; Legal Obligation |
| To comply with applicable laws and regulations, for any other purpose required by applicable laws or regulations or other purposes that you consent to | Legitimate Interest; Legal Obligation; Consent (where applicable) |
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by or via the Services, or due to the nature of such processing), your acceptance of our Terms of Service and of this Privacy Policy will be deemed 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 at privacy@tonkean.com.
3. Data Location
We and our authorized Service Providers (as defined in Section 5 below) maintain, store and process personal data in the United States, Europe, Israel and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, Tonkean is committed to protecting personal data in accordance with this Privacy Policy and 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 to which such data is transferred.
Tonkean is headquartered in the United States and Israel. Israel is a jurisdiction which is considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Secretary of State to offer an adequate level of protection for the personal data of residents of the EEA, Switzerland and the UK, respectively. We transfer personal data from the EEA, Switzerland and the UK to Israel on this basis. For data transfers from the EEA, Switzerland or the UK to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into valid transfer mechanisms, including the Standard Contractual Clauses (SCCs) as approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO). You can obtain a copy by contacting us as indicated in Section 11 below.
4. Data Retention
We retain personal data for as long as reasonably necessary for us to maintain and expand our relationship and provide you with our Services and offerings; to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (e.g., as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our contractual terms and data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at privacy@tonkean.com.
5. Data Disclosure
We disclose personal data in the following ways:
Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, website chat services, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Protecting Rights and Safety: We may disclose your personal data to others if we believe in good faith that this will help protect the rights, property or personal safety of Tonkean, any of our Users or Customers, or any members of the general public.
Service Integrations: The Platform includes features that integrate third-party services. Depending on the nature and purpose of these integrations, the provider of the integrated third-party service may receive certain relevant data about or from your account on our Platform. The third-party provider may also share certain relevant data from your account on their service with our Platform. This data may include your Customer Data and/or User Data. Note that we do not receive or store your passwords for any of these integrated third-party services, but we typically require your API key to facilitate the integration. Additionally, our Platform uses the Google Workspace API to enable certain features. If we receive any personal data from the Google Workspace API (“Google User Data”), we will only use it for the purpose of providing or improving our Services’ functionality and User-facing features. We will not use Google User Data for any other purposes, such as to develop, improve, or train generalized AI and/or machine learning models, nor in relation to cross-context behavioral advertising.
Business Customer: Our Customers have access to any personal data we process on their behalf in our capacity as a “processor”, “business associate” or a “service provider.”
Tonkean Subsidiaries and Affiliated Companies: We may disclose personal data internally within Tonkean’s group of subsidiaries and affiliates for the purposes described in this Privacy Policy. In addition, should Tonkean or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such event. If we believe that such a change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or a prominent notice on our Services.
For the avoidance of doubt, Tonkean may disclose your personal data in additional ways, such as pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, disclose or otherwise use non-personal data at our sole discretion and without the need for further approval.
For the purposes of the CCPA, in the past 12 months, we have disclosed: Identifiers, Professional or Employment-Related Information, Internet or other Electronic Network Activity Information, Customer Records Information, Commercial Information, Geolocation Data, Inferences from Personal Information Collected to the third-parties listed above. We do not use or disclose sensitive personal information outside of the purposes allowed by the CCPA.
6. Cookies and Data Collection Technologies
We and our Service Providers use cookies, pixels, tags and other technologies to provide and monitor our Services and Sites, to ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy.
While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookie preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
We also use the web analytics tool Google Analytics. This tool helps us understand users’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and interaction activities. Further information about the privacy practices of our analytics service provider is available at: www.google.com/policies/privacy/partners. Further information about your option to opt out of this analytics service is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt out, so an additional opt-out will be necessary to prevent additional tracking.
7. Communications
We engage in service and promotional communications, through e-mail, phone, notifications, and other communication services and/or platforms.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. If you are registered as a User to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Notifications and Promotional Communications: We may also contact you, through email or via the Intercom app, with promotional messages (such as newsletters, special offers and sales, new product announcements, etc.) or any other information we think our Customers will find valuable; and to facilitate, sponsor and offer certain events and promotions. We may provide such notices through any of the contact means available to us (e.g., phone or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Tonkean at any time by sending an email to privacy@tonkean.com, changing your communications preferences in your account, or by following the “” instructions contained in the promotional communications you receive.
8. Data Security
In order to protect your personal data held with us and our Service Providers, and on our networks, we use industry-standard physical, procedural, and electronic security measures, (such as access control, secure servers, firewalls, internal policies, encryption, database backup etc.). 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 our Service Providers, or any third parties that hold personal data about you on our behalf.
9. Data Subject Rights
Individuals have rights concerning their personal data. Please contact us by email at privacy@tonkean.com if you wish to exercise your rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR or UK GDPR, respectively) or the California Consumer Privacy Act (CCPA), such as (to the extent applicable): (i) to know/request access to personal data (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties to whom we have disclosed personal data), (ii) to request rectification or erasure of personal data held with us, (iii) to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data for targeted advertising), (iv) to port such personal data, or (v) to equal services and prices. You may also have the right to lodge a complaint with your local data protection authority. To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us. If you would like to make any requests or queries regarding personal data which we process on your organization’s (our Customer’s) behalf (i.e., Customer Data), please contact your organizational administrator directly.
Please note that when you or an authorized agent ask us to exercise any of your rights under this Privacy Policy or applicable law, we may need to ask you to provide us with certain credentials for authentication purposes, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access or have deleted. Such additional data will then be retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above.
We will acknowledge your request and provide a follow-up substantive response within a time period permitted by applicable law. We may redact from the data we make available to you, any personal data related to others.
10. Data Controller/Processor
Certain data protection laws and regulations, such as the EU and UK GDPR or CCPA, typically distinguish between two main roles for parties processing personal data. Under the GDPR or CCPA, the party that determines the purposes and means of the processing of personal data is considered the “data controller” or “business”, respectively. An entity that processes personal data on behalf of the controller/business is considered a “processor” or ”service provider” (respectively).
Tonkean is the “data controller” or “business” of Prospect Data and User Data as detailed in Section 1 above. Accordingly, we assume the responsibilities of a data controller/business (to the extent applicable under law), as set forth in this Privacy Policy. In such instances, each of our Service Providers processing such data will assume the role of a “data processor” or “service provider”.
Tonkean is the “data processor” or “service provider” of Customer Data. We process such data on behalf of our Customers and in accordance with their reasonable instructions, subject to our Terms of Service and the Data Processing Agreement with them. Accordingly, our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on their behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
11. Additional Notices & Contact Details
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After the notice period, all amendments shall be deemed accepted by you.
Opt out of Sale/Sharing for Targeted Advertising: Under some US data protection laws, like the CCPA, our disclosure of certain internet activity and device information with third parties through cookies may be considered a “sale” or “sharing” of personal information for targeted advertising. We do so in pursuit of the business and commercial purposes described in Section 2 above.
For the purposes of the CCPA, in the last 12 months we have “sold” or “shared” Internet or Other Electronic Network Activity Information, Geolocation Data, and Commercial Information with our analytics and advertising partners and service providers.
You may opt out of cookies that may result in a “sale” and/or “sharing” of your personal information in the following ways:
Click the “Do Not Sell or Share My Personal Information” button in the cookie banner (depending on your location), or in the “cookie settings” link on the website footer, then click the “OK” button.
Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third party advertisement, analytics or other cookies (instructions on how to download and use GPC are available here).
Children’s Privacy: Our Services are not designed to attract children who are underage according to data protection laws in their respective jurisdictions. We do not knowingly collect personal data from children and do not wish to do so, and we request that anyone underage refrains from providing their personal data to us. If you believe that we might have any such data, please contact us at privacy@tonkean.com. If we are made aware that a person who is underage according to the law applicable to them is using the Services, we will attempt to prohibit and block such use and will make all necessary efforts to delete any personal data stored with us with regard to that child, except where retention is required for legal purposes. For the purposes of the CCPA, Tonkean does not knowingly sell or share the personal information of individuals under the age of 16.
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website or service you visit. This Privacy Policy applies only to our Services.
Data Protection Officer: Tonkean has appointed PrivacyTeam Ltd. as our Data Protection Officer (DPO), for monitoring and advising on Tonkean’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, or 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 Tonkean, you can contact privacy@tonkean.com or our DPO at dpo@tonkean.com.
EU and UK Representative: Dr. Andreas Mätzler of Prighter has been designated as Tonkean’s representative in the European Union and United Kingdom for data protection matters pursuant to Article 27 of the GDPR or UK GDPR, as applicable. Inquiries regarding our EU privacy practices may be sent by e-mail to privacy@tonkean.com or via mail. EU inquiries may be sent to: Prighter (Attn: Tonkean), Schellinggasse 3/10, Vienna 1010, Austria. UK inquiries may be sent to: Prighter (Attn: Tonkean), 20 Mortlake High Street, London, SW14 8JN, United Kingdom.
Database Controller: For the purposes of Israel’s Protection of Privacy Law, Tonkean Inc. serves as the “Database Controller” for personal data processed in connection with this Privacy Policy that originates from Israel, and can be contacted at privacy@tonkean.com.
Questions, Concerns or Complaints: if you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Tonkean, please contact us at privacy@tonkean.com.
Last Updated: May 2026.