Table of contents:
1. What Information we Collect, Why we Collect it, and How it is Used
2. Period of Storage of Collected Personal Information
3. How we Protect your Personal Information
4. How we Share your Personal Information
5. Additional Information regarding Transfers of Personal Information
6. Your Privacy Rights
7. Use by Children
8. Interaction with Third Party Content, Products, Features and Services
9. Cookies and Other Technologies
10. Do Not Track Signal (California)
12. Contact Us
1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
· Online Identifiers. Apart from specific support cases or communication channels via which you contact us, the Services are not designed to personally identify any individual. However, certain types of the Services include collecting or generating an online identifier that associate a user with a device or with a session. The identifier parameter might vary as dependency of the type of use, and include cookie ID, user agent and an internal system parameter that we may randomly generate to a User visiting our Websites or using our Services, for as long as the User browses the Website (meaning, per session).
· Device and Technical Information. Certain technical information regarding your device, and your use of the Services, including, the device type and version number, name and version of operating system, and your configuration and settings of the device, including language and time zone.
· Online Activity. For compatibility purposes, usage analysis, analytics and purposes of serving content, including sponsored content and advertisement, we use web technologies such as cookies and pixel tags, including those of third parties, that may process information such as clicks across the Website, views and similar interactions you make with content and pages available to you via the Website or Services. For more information about how we use third-party technologies, see under Cookies and Other Technologies below.
· Usage Information. Certain analytics and usage related information regarding your use and interaction with the Services, your language settings, your engagement with elements and features of the Services, including button clicks and your interactions with advertisements.
The following describes how we use such information (also, the “Purpose”):
1. To provide you with the Services and related features, including providing you with relevant advertising. We also use certain data for fraud detection and prevention, and to assess the length of time of a user in our Services for service valuation purposes. We delete this data once our fraud and lifetime value assessment has been completed. For this purpose, we processes this information on the basis of your consent, which is freely and actively accepted by you when you first access and use our Services.
2. To detect and prevent fraud in our Services. We use such information to conduct fraud detection on potentially fraudulent and illegal uses of the Services, unauthorized access to the Website or, detect different forms of ad fraud. Once the fraud analysis assessment is completed, we will delete all data except for the Cookie-ID which we use for business performance analysis as described in the next paragraph or, until you choose to delete cookies by using your browser settings. For this purpose, we process this information on the basis of a legitimate interest for preventing fraud.
In performing fraud detection and prevention, we use the services of third parties who will receive and access such information as described in this Section.
3. To assess the effectiveness of our operations. We use such information to analyze performance and content-market fit, fix errors, and improve the usability and effectiveness of the Services. For this purpose, Company processes this information on the basis of a legitimate interest for its business operations and internal due diligence.
4. Customer Support.
We also use Support related information you provide to us to provide you with support and handle your request and/or feedback. This information will not be connected with any other information collected from you on or through the Services, including, any anonymous internal identifier generated or collected by us, unless you ask us to, or when it is required in order to process your request. For this purpose, we process this information on the basis of your consent, by actively reaching out to us, and voluntarily providing us with the information of your choice.
We will retain this information for the time it takes to provide you with the support you requested and to handle your complaints. We may keep your information for longer periods for service recording purposes, or in case of disputes and other legitimate reasons described in the next section “Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request”.
5. Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request.
We use your information and Support Related Information to take action in case of a dispute involving you in connection with the Services and to enforce the terms and conditions applicable to the Services. We also use your information to comply with legal and regulatory requirements (e.g., the disclosure of information to law enforcement or tax authorities), and to protect against suspicious or other illegal activities.
For this purpose, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g. to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of Company’s users, its partners, or the general public). We will also share this information with our professional advisors in the scope of this purpose.
We will retain this information for the amount of time as required by law to fulfil the above purposes. This may include ensuring that we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
Finally, please note that some of the abovementioned Personal Information 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 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. In certain cases, we may or will anonymize or de-identify your Personal Information.
2. PERIOD OF STORAGE OF COLLECTED PERSONAL INFORMATION
· Retention Personal Information. Except as provided above, your Personal Information will be stored until we: (i) no longer need the information to achieve the Purpose for which it was processed to begin with and proactively delete it or (ii) subject to applicable exemptions, you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws.
· Additional Information on Data Retention. Other circumstances in which we will retain your Personal Information for longer periods of time include: (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 Information or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Information perpetually. Regarding retention of cookies, you can read more under “Cookies and Other Technologies” below.
3. HOW WE PROTECT YOUR INFORMATION
We have implemented appropriate technical, organizational and security measures designed to protect your Personal 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, please make sure to take appropriate measures to protect this information.
4. HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your Personal Information as follows:
4.1. Third party service providers for purposes of hosting the Websites, related data, supporting and securing them and facilitating certain data operations. For example, Amazon Web Services (AWS) cloud.
4.2. Third party tools and services that enable easy and secure analysis of data, of usage of the Services and extracting business insights and metrics. For example, Google Analytics.
4.3. Third party content providers to which we provide media on our Websites and may make certain content available directly to you. For example, Taboola and Outbrain. In some cases, information we may share with third party advertisers, such as Google, will be used to serve personalized advertisement to you. In cases where such providers are visible to you, their content and services will be governed by their own privacy policies, made available to you directly from their content, features and services.
4.4. We may also share Personal Information with our affiliated companies.
4.5. 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;
In the event Company goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred; and/or
4.6. Where you have provided your consent to us sharing or transferring your Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
5. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION
5.1. Where we transfer your Personal Information outside of the EU/EEA, where applicable, for example to third parties who help provide our Services, we will obtain contractual commitments and or assurances from them to protect your Personal Information or rely on adequacy decisions issued by the European Commission. Some of these assurances are well recognized certification schemes. You can read more here:https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en; and
5.2. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.
6. YOUR PRIVACY RIGHTS
6.1. 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 the CCPA):
6.1.1. GDPR Rights: The following rights may apply to you if you are a resident of the EU, EEA or the UK. Please be noted that in some circumstances, we would not be able to accommodate your request if we cannot associate it with an anonymous user in our system, or, as the regulation may otherwise determine.
o You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
o You have the right to request that we rectify any Personal Information we hold that is inaccurate or misleading;
o You have the right to request the erasure/deletion of your Personal Information (e.g. from our records). 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;
o You have the right to object, to or to request restriction, of the processing of your Personal Information;
o You have the right to data portability. This means that you may have the right to receive your Personal Information in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
o You have the right to withdraw your consent to processing your Personal Information at any time, when our processing is based on such consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
o You also have a right to request certain details of the basis on which your Personal Information is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
o You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
6.1.2. CCPA Rights: The following rights may apply to you if you are a resident of California. Please be noted that in some circumstances, we would not be able to accommodate your request if we cannot associate it with an anonymous user in our system, if we cannot verify your request or your California residency, or, as the regulation may otherwise determine.
o You have the right to know what personal information is being collected about you in the twelve months preceding your request;
o 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;
o You have the right to know whether your personal information is sold or disclosed and to whom in the twelve months preceding your request; Please be noted that we do not sell your information.
o You have the right to equal service and price, even if you exercise your privacy rights;
o You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
6.2. Exercising your Rights. You can exercise your rights by contacting us here: email@example.com. 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.
7. USE BY CHILDREN
We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Information 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 Information to us. In the event that we become aware that you provided Personal 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 as provided below.
8. INTERACTION WITH THIRD PARTY CONTENT, PRODUCTS, FEATURES AND SERVICES
Our Websites and Services enable and host third party content, products and/or services that are not owned or controlled by us (each or jointly a “Third Party Content”). Third Party Content hosted on our Website or made available via the Services is provided directly by their owners or operators and governed by their own terms and privacy policies. Although we do require each such Third-Party Content to ensure full compliance and transparency, we are not responsible for the privacy practices or the content of such Third-Party Content. Please be aware that Third Party Content and related services may collect Personal Information from you based on your consent or their legitimate interest. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third-Party Content.
9. COOKIES AND OTHER WEB TECHNOLOGIES.
The Services collect or allow third parties to collect, through blocks of code called “pixels” or “web beacons”, certain information about your usage of the Services and send it to our servers and to our partners (either directly or indirectly). We or our partners, may package all or part of this information into small text files called Cookies and send the Cookie to your computer. As an example, Cookies may store the web pages you accessed, your interaction with advertisements presented to you via the Services, features you used, your session duration and your configurations and preferences of the Services. You can learn more about cookies on the Internet Advertising Bureau’s website: http://www.allaboutcookies.org.
Most browsers are initially set up to accept Cookies but you can reset your browser to refuse all Cookies or to indicate when a Cookie is sent. However, some functions of the Services may not function properly if your cookies are disabled.
You may also opt-out of Internet-Based Advertising (“IBA”) by member companies of the Network Advertising Initiative (NAI) by visiting the NAI website, or you may opt-out of IBA member companies of the Digital Advertising Alliance (DAA) by visiting the DAA website.
10. Do Not Track Signal (California).
Do Not Track is a privacy preference that can be configured in certain web browsers (the "DNT Feature"); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Company does not currently respond or recognize DNT Feature signals.
If you have any complaints on our processing of your personal information or if you believe that we have breached our own privacy policies or applicable law, we encourage you to contact us. However, please note that applicable EU data protection laws provide you with a right to lodge a complaint with the competent supervisory authority as well.
12. 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 firstname.lastname@example.org.