Last Updated: June 1, 2024

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Fullpath Ltd. (“Fullpath”, “AutoLeadStar” “we”, “our” or “us”) use, collect and store personal information that we collect or receive from or about you (“you”) in connection with our website https://www.fullpath.com/ (“Website”), platform, and the services provided therein (the “Services”):

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. Your customers’ information
3. How we protect and retain your Personal Information
4. How we disclose your Personal Information and for what purposes
5. Your privacy rights 
6. Use by children
7. Interaction with third party products
8. Analytic tools/ Cookies
9. Specific provisions applicable under California privacy law
10. Contact us

Fullpath’s mission is to take the typical customer data platform (CDP) to the next level by adding the “Experience” factor, layering AI-powered technology on top of dealership’s unified data layer, which allows dealers to create exceptional customer experiences through automated, AI-driven, highly effective engagements and marketing campaigns designed to drive sales and loyalty.

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 material changes in the way we use your information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.

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

1. We process the following categories of Personal Information:
   1. Cookies, analytic tools and log files.
   2. Identifiers. Such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
   3. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Such as name, address, telephone number.
   4. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
   5. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
   6. Geolocation / Location data (foreground or background data access). Physical location or movements.

2. We receive Personal Information from the following categories of sources:
   1. Information You Provide Directly to Us. We collect information you provide directly to us, including, without limitation, when you submit a request, submit an order, contact us, or request a demo. This includes name, email address, phone number, name of dealership, username and password. We collect information indirectly from you when you browse and make use of our Services.
   2. Information from Other Sources. Fullpath may also obtain information about you from other sources, including publicly – or commercially- available information, and through third-party data platforms, partners and service providers. We also collect information from your employers such as when your employers are our customers or service providers.
   3. Automatic Data Collection. We may automatically collect certain information through your use of the Fullpath Services, such as your Internet protocol (IP) address, browser and platform type, the date and time of your visit to the Website and/or Services, cookie identifiers and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of the Fullpath Services.

3. We process information for the following purposes:

1. 1. To provide you with the Fullpath Services. Fullpath will use your information to provide, support, personalize, and develop the Fullpath Website and Services.
   2. For Administrative Purposes. Fullpath may use your information (i) to contact you and respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) to provide you with the Fullpath Website and Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) to generally administer the Fullpath Website and Services; (vi)  to save you from re-entering the information when you access the Website and Services
   3. To Market the Fullpath Website and Services. Fullpath may use information to market the Fullpath Services. Such use includes (i) notifying you about offers and services that may be of interest to you; (ii) developing and marketing new products and services, and to measure interest in Fullpath’s Services; (iii) other purposes disclosed at the time you provide information; (iv) as you otherwise consent;
   4. Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; to maintain and secure your account and for security purposes. Furthermore, to enforce our terms of use including carrying out security reviews to validate your identity, age, contact details and, if applicable, your financial information. Information 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.
   5. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to analyze and improve Fullpath Services (including through the use of artificial intelligence) and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).
   6. Cookies and Similar Technologies. We, as well as third parties that provide different functionalities on the Fullpath Website and Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Fullpath Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Fullpath Website and Services. We use this information to improve our services, and to personalize your experience on our website. If you would like to opt out of the Technologies we employ on the Fullpath Website and Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.

2. YOUR CUSTOMERS’ INFORMATION

1. Fullpath has a contractual relationship with its clients (“Client”). In the context of the Platform and Services, the Client can upload or otherwise provide (at the Client’s discretion) information, and Personal Data to Fullpath which generally speaking belongs to the customers or leads of the Client (“Client Customers’ Information”).
2. For the avoidance of doubt, Fullpath is considered a “Processor” and the Client a “Controller” (as both such capitalized terms are defined in the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Personal Data Privacy and Online Monitoring Act (“CPDPA”), Utah Consumer Privacy Act (“UCPA”)) of such Client’s Users Information. Fullpath is considered a “Service Provider” and the Client a “Business” (as both capitalized terms are defined in California Consumer Privacy Act (“CCPA”)). Client is responsible for the security, integrity and authorized usage of Personal Data in the context of the Platform about the Client Customers’ Information, and also for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Data. Please note that Fullpath does not have any contractual relationship with the Client’s customers and users, therefore, Fullpath’s Clients are the responsible party for complying with all laws and regulations (including, without limitation, privacy laws) that apply to the collection and use of the Client Customers’ Information. If you are a Client’s customer or user and have any questions about your Personal Data, please contact the Client directly.
3. If your use of our Services includes processing “personal data” that is subject to the VCDPA, the CPA, CPDPA, or UCPA, or “personal information” that is subject to the CCPA, consisting of Client Customers’ Information, then the processing of such Client Customers’ Information shall be made in accordance with Fullpath’s Data Processing Addendum (“DPA”) that is available here.
4. In our provision of our services to our Clients, we also share some information of Client Customer’s Information with AI models:
   – The personal information that may be shared with any AI modes may include information such as names, phone numbers, addresses, email addresses.
   – Such personal information is used by AI models to generate tailored purchase recommendations and targeted online advertising.
   – The categories of AI models that personal information is shared with include ChatGPT and internal Fullpath models.

3. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION

1. Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. 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.
2. Retention of your information. Your information will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we may store your information 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, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION AND FOR WHAT PURPOSES

1. The information Fullpath gathers is disclosed to our business partners (resellers, representatives or/and other such third parties) for the purposes of providing our Services as well as for our internal administrative purposes.
2. We may also disclose information with our affiliated companies about you for the purposes of providing our Services as well as for our internal administrative purposes.
3. As stated above, we may disclose Client Customers’ Information as instructed by our Clients in order to comply with their instructions.
4. 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 in order to send marketing communications and to manage our interaction with customers;
   4. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy; and
5. 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 Fullpath, our Website and Services, customers, employees, property, and the public..
6. 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.
7. Where you have otherwise provided your consent to us for sharing or transferring your information.
8. If you want to receive the list of the current recipients of your Personal Information, please make your request by contacting us at privacyofficer@fullpath.com.

5. YOUR PRIVACY RIGHTS

1. Rights: Some applicable data protection laws grant you certain rights in connection with your Personal Information, the following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by such laws (including, individuals protected by the CCPA):

1. 1. You have the right to know what Personal Information is being collected about you, This include the right to request that we disclose what Personal Information of yours  we collect, use, disclose, and sell;
   2. You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
   3. You have the right to correct inaccurate Personal Information that we maintain about you.
   4. You have the right to know whether your Personal Information is sold or disclosed and to whom;
   5. You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
   6. You have the right to limit the processing of your sensitive Personal Information

2. You can exercise your rights by contacting us at privacyofficer@fullpath.com. If we decline to take action on one of your rights, applicable law may allow us to submit an appeal, this may be done by emailing us at privacyofficer@fullpath.com. You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you have authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using a consumer’s Personal Information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention. 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. If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights. 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.
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  privacyofficer@fullpath.com 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.

6. USE BY CHILDREN.

We do not offer our products or services for use by children under the age of 18, and we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information 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  privacyofficer@fullpath.com.

7. 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 information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. ANALYTIC TOOLS/COOKIES

1. 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 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/.
2. Mixpanel. We collect information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/.
3. Hotjar. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.  For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
4. FullStory. If you are a visitor of our Website, FullStory collects information on your use of the Website, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, and Internet Protocol address. FullStory uses publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. The purpose in collecting your usage data is to better understand how you use our Website. FullStory’s privacy policy is available here: https://www.fullstory.com/legal/privacy-policy/
5. Through our Services we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you.
6. We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

9. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

1.  Our California Do Not Track Notice: 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.

2. Our California Consumer Privacy Act (“CCPA”) privacy policy:
   1. Categories of Personal Information. The categories of Personal Information we collect are those listed in Section 1 (i) of this privacy policy.
   2. Categories of sources of Personal Information. The categories of sources we collect Personal Information from are those listed in Section 1 (ii) of this privacy policy.
   3. Purposes for collecting such Personal Information. The purposes for collecting such Personal Information are listed in Section 1 (iii) of this privacy policy.
   4. Third parties to whom we disclose Personal Information. The parties to whom we disclose your Personal Information and the purposes for such disclosure are listed in Section 4 of this privacy policy.
   5. Your Rights under the CCPA. If the CCPA applies to you, you may have the following rights:
      1. You have the right to know what Personal Information is being collected about you, This include the right to request that we disclose what Personal Information of yours  we collect, use, disclose, and sell;
      2. You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
      3. You have the right to correct inaccurate Personal Information that we maintain about you.
      4. You have the right to know whether your Personal Information is sold or disclosed and to whom;
      5. You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
      6. You have the right to limit the processing of your sensitive Personal Information
      7. Non-Discrimination. If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our website, our products and/or our services will not function without your Personal Information.
      8. You can exercise your rights by contacting us at privacyofficer@fullpath.com or, if you are an individual protected by CCPA, you can make your requests by email.  You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you have authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using a consumer’s Personal Information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention. 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.
   6. Notice of right to opt out of the sale or sharing of your personal information. We do not sell or share your personal information (as such terms are defined under the CCPA), therefore, in the preceding twelve (12) months, Fullpath has not sold or shared personal information.

10. 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 privacyofficer@fullpath.com.

Last Updated: June 1, 2024

Last Updated: June 1, 2024

Welcome to Fullpath!

This Website Terms of Use (the “Agreement“) applies to your (“you” and “your“) access to, and/or use of, https://www.fullpath.com and its subdomains (collectively, the “Website“). You must read this Agreement carefully, and by accessing or using the Website you confirm that you have read, understood, and agree to be bound by:

(A) these terms and conditions in their entirety; and

(B) any supplemental terms or policies in this Agreement which are stated to be incorporated into this Agreement (such as our Privacy Policy).

For the avoidance of doubt, this Agreement does not apply to the purchase or licensing (or other procurement) of any Fullpath products or services (such as subscribing to the Fullpath AI CDP software-as-a-service platform).

IF YOU ARE ENTERING INTO THIS AGREEMENT ON BEHALF OF AN ENTITY, YOU REPRESENT THAT YOU HAVE THE RIGHT, AUTHORITY, AND CAPACITY TO BIND SUCH ENTITY TO THIS AGREEMENT (AND ALL REFERENCES TO “YOU” AND “YOUR” SHALL REFER TO SUCH ENTITY).

IF YOU DO NOT AGREE WITH ANY OF THE TERMS AND CONDITIONS OF THIS AGREEMENT, YOU MAY NOT ACCESS OR USE THE WEBSITE.

YOU REPRESENT THAT YOU ARE AT LEAST EIGHTEEN (18) YEARS OLD, BUT IN ANY EVENT OF A LEGAL AGE TO FORM A BINDING CONTRACT. MINORS ARE NOT PERMITTED TO ACCESS OR USE THE WEBSITE.

This Agreement is a binding agreement between you and Fullpath Ltd. (“Fullpath“, “we“, “us“, and “our“).

Fullpath reserves the right to modify this Agreement at any time by posting the modified Agreement at https://www.fullpath.com/legal-and-trust/?nav=websiteterms. Such modifications will be effective upon posting (unless we specify a later effective date). In such cases, we will also update the “Last Updated” reference set forth at the beginning of this Agreement. Your continued use of the Website following the posting of revised Agreement means that you accept and agree to the changes. You are expected to check this page from time to time so you are aware of any changes, as they are binding on you.

1. DEFINITIONS AND INTERPRETATION

This Agreement contains a range of capitalized terms, some of which are defined in this Section and some of which are defined elsewhere. The Section headings in this Agreement are for convenience of reading only and may not to be used or relied upon for interpretive purposes.

“Fullpath Affiliate” means, with respect to Fullpath, any organization or entity controlling, controlled by, or under common control with, Fullpath, where “control” means the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of such person, organization or entity, whether through the ownership of voting securities, by contract, or otherwise.

“Fullpath Materials” means, collectively, the Website and any Content appearing or displayed on or in the Website. For the avoidance of doubt, and unless the context requires otherwise, references herein to Fullpath Materials includes without limitation Third Party Content (defined below).

“Content” means any text, data, information, images, graphics, sounds, videos, audio clips, links, and/or similar materials and content.

“Intellectual Property Rights” means any and all rights, titles, and interests (under any jurisdiction or treaty, whether protectable or not, whether registered or unregistered, and whether vested, contingent, or future) in and to inventions, discoveries, works of authorship, designs, software, technical information, databases, know-how, mask works, methods, technology, and other intellectual property (collectively, “Intellectual Property“), and includes but is not limited to patents, copyrights and similar authorship rights, moral (and similar personal) rights, mask work rights, data and database rights, trade secret rights and similar rights in confidential information and other non-public information, design rights, trademark, service mark, trade name, trade dress and similar branding rights, as well as: (i) all applications, registrations, renewals, reexaminations, extensions, continuations, continuations-in-part, provisionals, substitutions, divisions or reissues of or for the foregoing; and (ii) all goodwill associated with the foregoing.

“Law” means any federal, state, foreign, regional or local statute, regulation, ordinance, or rule, in any jurisdiction.

“Privacy Policy” means Fullpath’s then-current privacy policy available at https://www.fullpath.com/legal-and-trust/?nav=privacypolicy, as may be modified from time to time by Fullpath.

2. WEBSITE ACCESS

We hereby grant you a personal, limited, non-exclusive, non-assignable, non-sublicensable, revocable right and license to access, view and use the Website and related Fullpath Materials solely for your own personal and non-commercial use, and provided that you comply with this Agreement (collectively, the “License“). Except for the License, Fullpath does not grant you any right or license in or to any of Fullpath’s or a third party’s Intellectual Property Rights. In our sole discretion we may, at any time, with or without notice, and for any or no reason: (a) revoke the License, suspend the Website, and/or terminate this Agreement; and (b) modify, remove, and/or otherwise restrict access to (such as by geo-blocking), all or any part of the Website.

3. USAGE RESTRICTIONS 

As a condition to the License, you shall not (and shall not permit or encourage any third party to) do any of the following, in whole or in part: (a) copy or reproduce (such as by screen scraping), republish, create public Internet “links” to, “frame”, or “mirror” any Fullpath Materials, or otherwise access Fullpath Materials via any automated process; (b) sell, assign, lease, lend, rent, distribute, or make available any Fullpath Materials to any third party, or otherwise offer or use any Fullpath Materials as part of a time-sharing, outsourcing, or service bureau environment; (c) modify, adapt, arrange, translate, decompile, disassemble, reverse engineer, decrypt, or otherwise attempt to discover the source code or non-literal aspects (such as the underlying ideas, algorithms, structure, sequence, organization, and interfaces) of, any Fullpath Materials; (d) remove, alter, or conceal, in whole or in part, any copyright, trademark, or other proprietary rights notice or legend displayed or contained on or in any Fullpath Materials; (e) circumvent, disable or otherwise interfere with security-related or technical features or protocols of any Fullpath Materials; (f) make a derivative work of any Fullpath Materials, or use any Fullpath Materials to develop or create any service, product, or Content that is the same as (or substantially similar to or competitive with) any of the Fullpath Materials; (g) upload, publish, or transmit any “robots” or “spiders” (such as web crawlers), virus, malware, Trojan horse, spyware, or similar malicious item intended (or that has the potential) to damage or disrupt, or otherwise misuse, any Fullpath Materials; and/or (i) take any action that imposes or may impose (as determined in Fullpath’s sole discretion) an unreasonable or disproportionately large load on the Website infrastructure, or otherwise interfere (or attempt to interfere) with the integrity or proper working of any Fullpath Materials; (j) use any Fullpath Materials to infringe, misappropriate or violate any third party’s Intellectual Property Rights (as defined below), privacy (or other personal) rights), or any Law (such as to impersonate or attempt to impersonate any other person or entity); and/or (k) upload or publish any advertisement or promotional material on the Website.

4. LINKING TO OUR WEBSITE

Fullpath permits you to link to the Website provided that: (i) you link to (but do not replicate) any page on this Website; (ii) the hyperlink text shall accurately describe the Content as it appears on the Website; (iii) you shall not misrepresent your relationship with Fullpath or present any false information about Fullpath, and shall not imply in any way that we are endorsing you or any services or products, unless we have given you our express prior written consent to do so; (iv) you shall not link from a website which prohibits linking to third parties; (v) the website from which you link to the Website does not contain Content that is offensive or controversial (both as determined at our sole discretion), that infringes, misappropriates, or violates any Intellectual Property Rights; and (vi) you, and your website, comply with this Agreement and applicable Law.

5. THIRD PARTY CONTENT 

The Website may display, link to, and/or otherwise allow you to view, access, or interact with, Content from third parties and other sources that are not owned or controlled by Fullpath, even if they are Fullpath-branded or otherwise display Fullpath’s name or logo (such Content and third parties, “Third Party Content” and “Third Party Providers”, respectively). The Website may also enable you to communicate with the Third Party Providers. For example, the Website may display links to, or otherwise contain embedded links to, distributor or supplier websites that distribute or supply the Fullpath products.

The display or communication to you of such Third Party Content does not (and shall not be construed to) in any way imply, suggest, or constitute any sponsorship, endorsement, or approval by Fullpath of such Third Party Content or Third Party Provider, or by such Third Party Provider of Fullpath, and nor any affiliation between Fullpath and such Third Party Provider.

Fullpath does not assume any responsibility or liability for Third Party Content, or any Third Party Provider’s terms of use, privacy policies, actions, omissions, or practices. Please read the respective terms of use and privacy policies of any Third Party Provider that you interact with before you engage in any such activity.

6. RESPONSIBILITY FOR YOUR CONTENT  

If you provide, publish, upload, or transmit any Content to or via the Website (“Your Content”), you represent and warrant as follows: (A) Your Content will be complete and accurate; (B) no processing of Your Content under this Agreement (whether by Fullpath, Third Party Providers, or subprocessors) will violate any Law, proprietary right, or privacy (or other personal) right; (C) you have obtained and will maintain all required consents and licenses, and will maintain all ongoing legal bases under relevant privacy Laws (if applicable), necessary to so provide, publish, upload, and transmit Your Content; and (D) Your Content will not contain or link to any violent, obscene, or unlawful Content.

By submitting the Your Content to Fullpath, you hereby grant Fullpath a worldwide, irrevocable, non-exclusive, royalty-free, perpetual, sublicensable (through multiple tiers), and transferable right and license to use, reproduce, distribute, prepare derivative works of, publicly display, and publicly perform the Your Content in connection with the Website and Fullpath’s business, including without limitation for publishing and redistributing part or all of Your Content (and derivative works thereof) in any media formats and through any media channels and, and you hereby waive any moral rights in or to Your Content, to the extent permitted by law.  You also hereby grant each user of the Website, as well as other viewer or user of You Content, a non-exclusive right and license to use, reproduce, distribute, prepare derivative works of, display and perform Your Content, all in accordance with this Agreement.

7. INTELLECTUAL PROPERTY

As between you and Fullpath, Fullpath (and/or its licensors and suppliers, as applicable) is and shall remain the sole and exclusive owner of all right, title, and interest (including, but not limited to, all Intellectual Property Rights) in and to:

1. the Fullpath Materials, as well as any computer programs (including APIs), code, databases, or other Intellectual Property underlying, operating, or otherwise embodied in any Fullpath Materials; and
2. the trademarks, service marks, trade names, service names, trade dress, symbols, brands, and logos displayed on contained on or in any Fullpath Materials (“Trademarks”).

You acknowledge that the items in paragraphs (a) and (b) above may be protected by Intellectual Property Rights treaties and Laws. Without limiting paragraph (b) above, Fullpath™, AutoLeadStar™, and their respective logos and design, are the Trademarks of Fullpath. Other Trademarks displayed on contained on or in any Fullpath Materials are the property of their respective third party owners.

Except for the License, Fullpath (and its licensors and suppliers, as applicable) reserve all rights in and to their respective Intellectual Property Rights. Any right not expressly granted to you in this Agreement are hereby reserved by Fullpath and its Affiliates, licensors and suppliers.

8. WARRANTY DISCLAIMERS

THE FULLPATH MATERIALS ARE PROVIDED AND MADE AVAILABLE TO YOU ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITH ALL FAULTS, AND WITHOUT ANY REPRESENTATION, WARRANTY, GUARANTEE OR CONDITION OF ANY KIND WHATSOEVER, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING WITHOUT LIMITATION ANY IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, SATISFACTORY QUALITY, QUIET POSSESSION, TITLE, NON-INFRINGEMENT, OR THAT OTHERWISE ARISE FROM A COURSE OF PERFORMANCE OR DEALING, OR USAGE OF TRADE, ALL OF WHICH ARE HEREBY DISCLAIMED BY FULLPATH AND ITS LICENSORS AND SUPPLIERS. NO ORAL OR WRITTEN INFORMATION OR ADVICE GIVEN BY OR ON BEHALF OF FULLPATH SHALL CREATE OR GIVE RISE TO A REPRESENTATION, WARRANTY, GUARANTEE, OR CONDITION. ANY USE OF, OR RELIANCE UPON FULLPATH MATERIALS IS AT YOUR SOLE RISK.

IN ADDITION, NEITHER FULLPATH NOR ITS LICENSORS OR SUPPLIERS MAKE ANY REPRESENTATION, WARRANTY, GUARANTEE, OR CONDITION:

1. REGARDING THE EFFECTIVENESS, USEFULNESS, RELIABILITY, AVAILABILITY, TIMELINESS, ACCURACY, OR COMPLETENESS OF ANY FULLPATH MATERIALS;
2. THAT YOUR USE OF, OR RELIANCE UPON, FULLPATH MATERIALS WILL MEET YOUR REQUIRMENTS OR EXPECTATIONS;
3. THAT FULLPATH MATERIALS WILL BE UNINTERRUPTED, SECURE, ERROR-FREE OR VIRUS-FREE, OR THAT DEFECTS WILL BE CORRECTED;
4. REGARDING THE SATISFACTION OF, OR COMPLIANCE WITH, ANY INDSUTRY STANDARDS; OR
5. REGARDING THE OPERATION OF ANY CELLULAR NETWORKS, THE PASSING OR TRANSMISSION OF DATA VIA ANY NETWORKS OR THE CLOUD, ANY CYBERSECURITY EVENT, OR ANY OTHER CELLULAR OR DATA CONNECTIVITY PROBLEMS.

FULLPATH WILL NOT BE LIABLE OR OBLIGATED IN RESPECT OF DELAYS, INTERRUPTIONS, SERVICE FAILURES OR OTHER PROBLEMS INHERENT IN USE OF THE INTERNET AND ELECTRONIC COMMUNICATIONS OR FOR ISSUES RELATED TO HOSTING PROVIDERS OR PUBLIC NETWORKS.

The above disclaimers apply to the maximum extent permitted by applicable Law. You may have legal rights in your country of residence which would prohibit the above disclaimers from (fully or partially) applying to you (for example, some jurisdictions’ Laws do not allow the disclaimer of certain implied warranties or conditions, and do not allow limitations to be imposed on statutory rights), and, to the extent the above disclaimers are prohibited, then you and Fullpath agree that they will not apply to you.

YOU ARE SOLELY RESPONSIBLE AND LIABLE FOR ALL INFORMATION AND DATA YOU PROVIDE, AND YOU REPRESENT AND WARRANT THAT SUCH INFORMATION AND DATA WILL NOT INFRINGE OR VIOLATE ANY THIRD PARTY’S PROPRIETARY RIGHTS OR PRIVACY RIGHTS, OR ANY APPLICABLE LAW.

9. LIMITATION OF LIABILITY

IN NO EVENT SHALL FULLPATH, ANY OF FULLPATH’S AFFILIATES, OR ITS OR THEIR RESPECTIVE LICENSORS OR SUPPLIERS BE LIABLE UNDER, OR OTHERWISE IN CONNECTION WITH, THIS AGREEMENT, FOR:

1. ANY CONSEQUENTIAL, INDIRECT, SPECIAL, INCIDENTAL, OR PUNITIVE DAMAGES;
2. ANY LOSS OF PROFITS, LOSS OF BUSINESS, LOSS OF REVENUE, LOSS OF ANTICIPATED SAVINGS, LOSS OF OPPORTUNITY, WASTED TIME OR EXPENDITURE, OR OTHER ECONOMIC LOSS;
3. ANY LOSS OF, OR DAMAGE OR INTERRUPTION TO, DATA, NETWORKS, INFORMATION SYSTEMS, REPUTATION, OR GOODWILL; AND/OR
4. THE COST OF COVER, OR OF PROCURING ANY SUBSTITUTE GOODS OR SERVICES.

THE COMBINED AGGREGATE LIABILITY OF FULLPATH AND ALL FULLPATH AFFILIATES UNDER, OR OTHERWISE IN CONNECTION WITH, THIS AGREEMENT SHALL NOT EXCEED FIVE US DOLLARS (US$ 5).

THE FOREGOING EXCLUSIONS AND LIMITATIONS SHALL APPLY: (i) TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW (SUCH AS, FOR EXAMPLE, IF A JURISDICTION DOES NOT ALLOW THE EXCLUSION OR THE LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, OR OF LIABILITY FOR PERSONAL INJURY OR DEATH CAUSED BY NEGLIGENCE); (ii) EVEN IF A FULLPATH HAS BEEN ADVISED, OR SHOULD HAVE BEEN AWARE, OF THE POSSIBILITY OF LOSSES, DAMAGES, OR COSTS; (iii) EVEN IF ANY REMEDY IN THIS AGREEMENT FAILS OF ITS ESSENTIAL PURPOSE; AND (iv) REGARDLESS OF THE THEORY OR BASIS OF LIABILITY, INCLUDING WITHOUT LIMITATION BREACH OF WARRANTY, NEGLIGENCE, MISREPRESENTATION, STRICT LIABILITY, OR OTHER CONTRACT, TORT OR STATUTORY LIABILITY.

To the maximum extent permitted by applicable Law, you hereby irrevocably release Fullpath, all Fullpath Affiliates, and its and their respective directors, officers, members, employees, representatives, consultants, agents, suppliers and/or distributors from all responsibility, liability, claims, demands and/or damages of every kind and nature, known and unknown, arising out of or in any way connected with: (x) disputes between or among users of the Website; and (y) Third Party Providers and Third Party Content. If you are a California resident, you hereby irrevocably waive the applicability of California Civil Code §1542, and any similar statute or principle of common law. California Civil Code §1542 says: “A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of executing the release, which if known by him or her must have materially affected his or her settlement with the debtor.”

10. INDEMNIFICATION

You agree to defend, indemnify and hold harmless Fullpath and Fullpath Affiliates, and our respective officers, directors, employees and agents, from and against any and all claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to your breach of this Agreement, your use of Fullpath Materials other than as expressly authorized in this Agreement, or your use of any information obtained from the Website.

11. MISCELLANEOUS
    1. Entire Agreement. This Agreement represents the entire agreement between you and Fullpath with respect to the subject matter hereof, and supersedes and replaces any and all prior and contemporaneous oral and/or written agreements, understandings and statements between you and Fullpath with respect to such subject matter. You acknowledge and agree that in entering into this Agreement you have not relied on any statement or representation (whether negligently or innocently made) not expressly set out in this Agreement, such as statements and explanations in any FAQs, summaries or explanatory guides regarding this Agreement, or other marketing material on the Website.
    2. Governing Law. This Agreement (including without limitation its validity) shall be governed by, and construed in accordance with, the laws of the State of Israel without regard to any conflicts of laws rules or principles. The United Nations Convention on Contracts for the International Sale of Goods shall not apply to this Agreement and is hereby disclaimed.  You agree to submit to the personal and exclusive jurisdiction of the courts located in Tel Aviv-Jaffa and waive any jurisdictional, venue, or inconvenient forum objections to such courts, provided that Fullpath may seek equitable relief in any court of competent jurisdiction. TO THE MAXIMUM EXTENT PERMITTED BY LAW, YOU AGREE THAT ANY CAUSE OF ACTION THAT YOU MAY HAVE ARISING OUT OF OR RELATED TO THE SITE MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY BARRED. Any claims or damages that you may incur hereunder shall only be enforceable against Fullpath, and not any other entity (such as Fullpath Affiliates) or Fullpath’s officers, directors, representatives, employees, or agents. Moreover, if you are a consumer (as defined in the Law of your jurisdiction), this Agreement is not intended to, and shall not, exclude or limit any mandatory rights you may have under the consumer protection Laws of your jurisdiction.
    3. Language; Electronic Contract and Communications. The language of this Agreement is expressly agreed to be the English language. You hereby irrevocably waive, to the maximum extent legally permitted, any Law applicable to you requiring that the Agreement be localized to meet your language (as well as any other localization requirements), or requiring an original (non-electronic) signature or delivery or retention of non-electronic records. We may be able (but are not obligated) to provide you with copies of this Agreement on written request; however, please be sure to print a copy of this Agreement for your own records. When you visit or submit information on the Website or send an email to us, you are communicating with us electronically. You consent to receive communications from us electronically. Although we may choose to provide you notice under this Agreement by postal mail, we may also choose to provide notice by email (in which case the notice will be deemed given on the day after sending) and/or by posting notices on the Website (in which case the notice will be deemed given when you access the Website). In addition, you acknowledge and agree that when you click on any “SUBMIT”, “I AGREE”, “I ACCEPT”, or similar button, through which you submit information, you are submitting a legally binding electronic signature. Pursuant to any applicable Laws, including without limitation the United States Electronic Signatures in Global and National Commerce Act, P.L. 106-229 (the “E-Sign Act“) or other similar statutes, YOU HEREBY AGREE TO THE USE OF ELECTRONIC SIGNATURES, CONTRACTS, ORDERS AND OTHER RECORDS AND TO ELECTRONIC DELIVERY OF NOTICES, POLICIES AND RECORDS OF TRANSACTIONS INITIATED OR COMPLETED THROUGH THE WEBSITE OR SERVICES OFFERED BY FULLPATH.
    4. Assignment. Fullpath may assign this Agreement (or any of its rights and/or obligations hereunder) without your consent, and without notice or obligation to you. This Agreement is personal to you, and you may not assign (or in any other way transfer) this Agreement (or any of its obligations or rights hereunder) without Fullpath’s express prior written consent. Any prohibited assignment shall be null and void.
    5. Feedback. If you send us any suggestions, feedback, or similar ideas for or about any Fullpath Materials (collectively, “Feedback“), you agree that: (a) Fullpath exclusively owns (and is hereby assigned) all right, title, and interest (including without limitation all Intellectual Property Rights) in and to the Feedback, and you are not owed any compensation (or other obligation) in exchange; (b) the Feedback does not contain confidential or proprietary information belonging to you or any third party; (c) Fullpath may (itself and/or via third parties), in perpetuity, use, copy, distribute, sell, create derivative works of, and otherwise commercially exploit the Feedback for any purpose and in any way, and without any restriction or obligations of any kind whatsoever; (d) there is no obligation for us to review your Feedback; and (e) Fullpath has no obligation to keep the Feedback confidential.
    6. Severability. If any provision of this Agreement is held by a court of competent jurisdiction to be illegal, invalid or unenforceable, then: (a) the remaining provisions of this Agreement shall remain in full force and effect; and (b) the Parties hereto agree that the court making such determination shall have the power to limit the provision, to delete specific words or phrases, or to replace the provision with a provision that is legal, valid and enforceable and that most closely approximates the original legal intent and economic impact of such provision, and this Agreement shall be enforceable as so modified in respect of such jurisdiction. In the event such court does not exercise the power granted to it as aforesaid, then such provision will be ineffective solely as to such jurisdiction, and will be substituted (in respect of such jurisdiction) with a valid, legal and enforceable provision that most closely approximates the original legal intent and economic impact of such provision.
    7. Remedies. Except as may be expressly stated otherwise in this Agreement, no right or remedy conferred upon or reserved by any party under this Agreement is intended to be, or shall be deemed, exclusive of any other right or remedy under this Agreement, at law or in equity, but shall be cumulative of such other rights and remedies.
    8. Privacy. Our Privacy Policy, which is hereby incorporated into, and made a part of, this Agreement by reference.
    9. Waiver. No failure or delay on the part of any party in exercising any right or remedy under this Agreement shall operate as a waiver thereof, nor shall any single or partial exercise of any such right or remedy preclude any other or further exercise thereof or the exercise of any other right or remedy. Any waiver granted hereunder must be in writing (for waivers by you, emails will be acceptable; for waivers by Fullpath, the writing must be duly signed by an authorized representative of Fullpath), and shall be valid only in the specific instance in which given.
    10. Relationship. The relationship of the parties is solely that of independent contractors. Nothing in this Agreement shall be deemed to create any employment, fiduciary, joint venture, agency or other relationship between the parties.
    11. Notices to Fullpath. Except as stated otherwise in this Agreement, you agree to send all Agreement-related notices to Fullpath, to legal@fullpath.com
    12. No Third Party Beneficiaries. Except as may be expressly provided otherwise in this Agreement (such as Fullpath Affiliates, Fullpath licensors and suppliers, and Indemnitees), there shall be no third-party beneficiaries of, or under, this Agreement, and no third party shall be entitled to enforce any of these terms and conditions.
    13. Export Compliance. You represent and warrant that: (a) you are not a resident of (and you will not use the Website in) a country that the U.S. or any other relevant government has embargoed for use of the Website, nor are you named on a governmental list of specially designated nationals or any other applicable trade sanctioning regulations of any jurisdiction; and (b) your country of residence and/or incorporation (as applicable) is the same as the country specified in the contact and/or billing address provided to us.
    14. Force Majeure. Neither party shall be responsible for any failure to perform any obligation hereunder because of any (a) act of God, fire, flood, earthquake, explosion, or pandemic or epidemic (or similar regional health crisis); (b) strikes, lockouts, picketing, concerted labor action, or other labor or industrial disturbances; (c) invasion, war (declared or undeclared), terrorism, riot, insurrection, or civil commotion; (d) war (declared or undeclared), terrorism, riot or civil commotion; and/or (d) other similar cause beyond that party’s reasonable control.
    15. California Users. If you are a California resident, we are required to inform you that you may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs via mail at 1625 North Market Blvd., Suite N112, Sacramento, CA 95834 or telephone at (916) 445-1254 or (800) 952-5210. Hearing-impaired users can reach the Complaint Assistance Unit at TDD (800) 326-2297 or TDD (916).
    16. Subpoenas. Nothing in this Agreement prevents Fullpath from disclosing your information or data to the extent required by Law, subpoenas, or court orders.

Welcome to the Fullpath Security Center, where we outline our commitment to safeguarding your information and ensuring the highest standards of data privacy. Here, you can learn about the steps Fullpath takes to protect our customers and the robust measures we have in place to maintain the security and integrity of our systems.

Our Commitment to Security

We recognize the growing importance of robust information security and the rising threats to data privacy. To address these concerns, Fullpath has adopted ISO 27001, an internationally recognized standard for information security management, ensuring that your data is always protected.

Senior Management Support

Fullpath’s senior management is fully committed to improving our security footprint. Management ensures that the necessary resources are allocated to implement a comprehensive security paradigm, adhering to best practices and ensuring the protection of our critical assets, systems, and processes.

Risk Assessment and Treatment

Fullpath conducts comprehensive risk assessments to identify potential threats and vulnerabilities within our information systems. Based on these findings, we develop a risk treatment plan outlining strategies to mitigate, transfer, accept, or avoid the identified risks.

Security Policies and Controls

Fullpath has formulated an overarching security policy defining our commitment to information security. Our security controls cover various domains, including:

• Access Control: Ensuring that only authorized personnel can access sensitive information and systems.
• Cryptography: Protecting data both at rest and in transit with encryption techniques.
• Physical Security: Implementing measures to protect facilities and hardware.
• Operations Security: Managing and protecting information processing.
• Communications Security: Securing networks and communication channels.
• System Development and Maintenance: Integrating security requirements into the lifecycle of information systems.
• Supplier Relationships: Ensuring third-party suppliers and partners adhere to security requirements.
• Incident Management: Developing processes to detect, respond to, and recover from security incidents.
• Business Continuity: Establishing plans to ensure the availability of critical operations.
• Compliance: Adhering to legal, regulatory, and contractual obligations related to information security.

Training and Awareness

Fullpath conducts regular training and awareness programs to ensure all employees understand their roles in maintaining security. These programs emphasize the importance of our security policies, procedures, and best practices.

Continuous Monitoring and Improvement

At Fullpath we continuously monitor and review our security management system to assess the effectiveness of our security controls. Regular internal audits and reviews help us identify areas for improvement and ensure compliance with our security standards.

Incident Management

Fullpath has a well-defined incident management process in place to respond promptly and effectively to security breaches or incidents. This process includes incident detection, reporting, investigation, and remediation steps.

Software Security Development Lifecycle (SSDLC)

At Fullpath we integrate security into every phase of our software development lifecycle to ensure our products are secure by design. If you discover a security bug or vulnerability, please report it to us at security@fullpath.com. Your reports help us maintain the highest standards of security for our products and services.

Certification and Compliance

Fullpath has, since 2020,  achieved formal ISO 27001 certification for our security management system, ensuring compliance with international standards. To maintain our certification, we commit to regular surveillance audits and recertification audits, continually improving our security measures.