Privacy Policy
Last Updated: 10th September 2023

This privacy policy (“Privacy Policy”) governs how we, Pragmatica Ltd. (together, “Pragmatica” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“you”) when you make use of, or interact with, our tool, mobile software application, and any other mobile software application, that we license (each individually, and collectively, the “Pragma”).

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. For example, the legal basis in the table below is only relevant to GDPR-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. 

Table of contents

  1. What information we collect, why we collect it, and how it is used
  2. Customer Information
  3. AI Functionalities and Pragma Chatbot
  4. How we protect and retain your Personal Data
  5. How we share your Personal Data
  6. Additional information regarding transfers of Personal Data
  7. Your privacy rights
  8. California privacy rights
  9. Use by children
  10. Interaction with third party products
  11. Log files 
  12. Analytic tools
  13. 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.


When you download, activate and/or use Pragma:

When you browse and/or interact with our Website, (“Website”)

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. We have a contractual relationship with our customers (“Customer”). In the context of the Pragma services, the Customer shares with us, and we access, Personal Data about the clients, prospective clients or other parties that interact with the Customer ("Customer Information").  
  2. For the avoidance of doubt and as applicable, we are considered a “Processor” (as such capitalized term is defined in the European Union General Data Protection Regulation (“GDPR”)), and/or, as applicable, “Service Provider” (as such capitalized term is defined in The California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act  of 2020 ("CPRA") (together, the "CCPA")) of such Customer Information. Customer is responsible for the security, integrity and authorized usage of Customer Information in the context of our services, and also for obtaining consents, and permissions, and providing any required data subject rights and fair processing notices required for the collection, processing, usage, and for allowing us access to such Customer Information. Please note that we do not have any contractual relationship with the Customer’s clients, prospective clients, or other parties with whom the Customer interacts, therefore, the Customer is the responsible party for complying with all laws and regulations (including, without limitation, privacy laws) that apply to the Customer Information. If you have any question about your Personal Data included within Customer information, please contact the Customer directly.


As part of the Services, Pragma may provide You with various AI-enabled features and functionalities (“AI Functionalities”), including an AI-generated chatbot ("Chatbot"). The AI Functionalities and the Chatbot could involve integrations with third parties, such as OpenAI. Pragma may provide You with AI Functionalities which may include, without limitation, OpenAI LLC (“OpenAI”) language-generation models ("GPT"), incorporated into the Chatbot to be used as a tool to create automatically generated tickets, answers to questions, descriptions, instructions, and other texts. You may use the AI Functionalities only in supported geographies. For the purpose of providing you with the AI Functionalities and/or the Chatbot, Pragma may integrate data from your company’s information. You acknowledge, instruct, and agree to Pragma's use of Your information and data to train Your designated Chatbot (including, without limitation, customer tickets and other forms of content or data). Such Chatbot will be offered as a customized version for Your use. For clarity, Pragma does not share Your information with other customers, and it uses Your information solely for the purposes of providing the Chatbot and AI Functionalities to You. You shall obtain and maintain all necessary consents, rights and permits and provide all necessary notices for such use of Your information by us. In connection with your use of the AI Functionalities and/or the Chatbot, You may provide input (“Input”), and receive output generated and returned by the AI Functionalities and/or the Chatbot based on the Input (“Output”). You acknowledge that you are not required by law or otherwise to provide any specific Input and that any Input is provided on a voluntary basis. In addition, You acknowledge that the Output is subject to, depends on, and is a function of the Input. You acknowledge that any Output may not be unique. As between You and Pragma, Pragma and its third-party technology providers and licensors (including, without limitation, OpenAI), as applicable, own and reserve all legal right, title and interest in and to the AI Functionalities, including all intellectual property and proprietary rights. You may not use AI Functionalities and/or the Chatbot to create or share Output in a manner that violates this document and/or any third-party policies, such as OpenAI policies, including, without limitation, their Content Policy; Usage Policy, Sharing and Publication Policy, Community Guidelines, and Open AI Terms, which apply to the use of OpenAI. The AI Functionalities, Chatbot, and the Outputs are provided to the Customers on an "as is" and "as available" basis. Pragma disclaims all express warranties and all implied warranties, including merchantability and fitness for a particular purpose. You shall be the sole responsible for the Input and the Output provided. You acknowledge that no security measures can fully prevent all potential loss, misuse or alteration of personal and other information provided as Input, and therefore, Pragma and any of its affiliates shall, to the fullest extent permitted by law, not be liable for any potential losses or damages arising as a result of the Chatbot and AI Functionalities. You shall not: (i) use output from the AI Functionalities and/or the Chatbot to develop models that compete with  Pragma and/or OpenAI; (ii) use the AI Functionalities and/or Chatbot to process any health information, Personal Information, financial information or any other category of Confidential Information or sensitive information, as defined under applicable laws (iii) disclose to any third party information related to the AI Functionalities and/or the Chatbot (which shall all be considered Pragma's Confidential Information) (iv) use any automated or programmatic method to extract data or output from the AI Functionalities, including scraping, web harvesting, or web data extraction; (v) represent that output from the AI Functionalities and/or the Chatbot was human-generated when it is not or otherwise violate this Agreement and the OpenAI Usage Policies; (vi) send or process any personal information of children under 13 or the applicable age of digital consent in connection with the AI Functionalities and/or the Chatbot; or (vii) use any AI Functionalities and/or the Chatbot in violation of applicable laws or third-party rights or for unethical purposes.


  1. Security. We have implemented industry standard 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. In addition to the retention periods mentioned above, 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. All information will be kept for a period of three years, or earlier, following a deletion request.


We may share your Personal Data as follows:

  1. With our service providers in order to offer our products and/or services. We may also share Personal Data with our affiliated companies.
  2. To the extent necessary, with regulators, courts 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;
  3. 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 Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
  4. 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 Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or 
  5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).



  1. Storage: We store the Personal Data with the following storing companies: Google Cloud, Amazon Web Services, Salesforce.

  1. Transfers (GDPR only, to the extent applicable): Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When Pragmatica engages in such transfers of personal information, it generally relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. 


  1. Rights: 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 the GDPR or by CCPA, if applicable):

  1. You can exercise your rights by contacting us at  You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. 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 require 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 initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law. 

  1. Deleting your account: Should you ever decide to delete your account, you may do so by emailing


  1. In some contexts, the CCPA permits users who are California residents to request to exercise certain rights. Subject to its applicability to Pragma, and to the extent that you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to your Personal Data. In particular, you can request to receive information on the following:
  1. We do not sell nor share your Personal Information. If you choose to exercise your rights, we will not charge you different prices or provide different quality of our Services, unless those differences are related to your provision of your Personal Information.

  1. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Moreover, you may designate an authorized agent to make a request on your behalf. 

  1. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide, will only cover the 12 month period preceding your verifiable request's receipt. If, for some reason, we cannot reply within such time frame, our response will include an explanation for our inability to comply. If you wish to exercise your CCPA rights, please contact us at:

  1. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  1. If at any time you would like to unsubscribe from receiving future emails, you can email us at we will promptly remove you from our correspondence.
  2. Other California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to Please note that we are only required to respond to one request per customer each year.

  1. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers


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. 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


We may 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.


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


We reserve the right to remove or add new analytic tools.


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

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