[Last Revised: November 11, 2018]
In general, and as shall be detailed in this Policy, the basis on which we collect and process user’s data is as follows: (i) we process user’s personal data in the event we have a legitimate interest to do so (e.g., IP); (ii) we process user’s personal data in order to perform a contract, in the event a user have signed up to our Services; or (iii) we process user’s personal data in the event we have obtained the user’s consent for such processing, in the event applicable.
We encourage you to review this Policy before you use the Services or browse the Website.
(2) POLICY UPDATES
We may, at our discretion, update or amend this Policy, at any time. Any amendments shall be effective upon publication of the revised Policy. The last revision will be reflected in the “Last Revised” heading. In the event of what we believe as material amendments we will make best efforts to provide applicable notification. Please review this Policy periodically. Your continued use of the Services following any updates or revisions to this Policy constitutes you consent to such changes.
(3) TYPES OF DATA COLLECTED THROUGH THIS WEBSITE AND OUR USE OF SUCH DATA
Whenever a user access this Website and use the Services available therein, we may collect the following types of data:
(i) Non-Personal Data – meaning,non-identifiable aggregated data, mainly technical data transmitted by the user’s device and aggregated use of the Services. This data is not used to identify individual users.
(ii) Personal Data –meaning, individually identifiable information.
The table below was designed in an easy to read format, in order for you to easily understand how we use the data collected through this Website:
|Contact Details. when a user contacts us by any means of communications (i.e., through the Website’s online form or by sending us an email) it will be requested to provide us its contact details such as name, email address, or phone number.||These contact details will be used by us solely in order to respond to the user’s request and provided the needed information or support. In some cases, when we believe it is needed, we will save the applicable contact history.|
|IP and Technical Non-Personal Data. the technical Non-Personal Data we collect includes, among others, software and hardware information, type of operating system, type of device, type of browser, language preference, the time and date you access and use the Services, internet service provider, navigation in the Website and duration of your visit, statistical browsing information, approximate geographical location (extracted through IP), directing URLs, etc.
With regards to IP address, note that this data is considered Personal Data in many territories (such as the EEA), however it is not considered as Personal Data in other jurisdictions. The Company will treat such IP as Personal Data, in accordance with applicable laws.
|This data will be used by us to fulfil our legitimate interests of: tracking usage statistics and traffic flow related to our Website; improve and customize our Website and Services as well as remarketing (as detailed below); operate, maintain, protect and manage our Website and Services.|
Note that, we do not combine Personal Data voluntarily provided by you with the Non – Personal Data. However, if we do so, we will treat the combined information as Personal Data.
(4) HOW DO WE COLLECT DATA?
We gather some information automatically through the use of third parties’ cookies and similar tracking technologies (“Cookies”), placed within the Website. “Cookies” are small text files that are placed on your device or browser by a web server when you access our Website.
|Google AdWords||Used for advertising & remarketing. Our use of these services is intended to serve relevant ads tailored to you based on the webpages you have viewed by placing a cookie on your device (i.e., will show you ads relating to that webpage).||https://policies.google.com/privacy|
|Google Analytics||Used in order to track and analyse the use of our Website, and for statistical internal purposes, such as, to know how many users have accessed our Website.||www.google.com/policies/privacy/partners|
|MaxMind||GEO Location Services.||https://www.maxmind.com/en/privacy_policy|
|TrafficTune||We use our cookies to operate the website and trach performance of our campaigns.|
For additional information of our use of Google products, click here.
Note that, you may be able to disable some cookies through your device or browser settings. In the event you disable cookies, some features of our Services may not operate properly. More information about your ability to disable cookies, can be found here (as applicable to your browser): Google Chrome; FireFox; Internet Explorer; Safari; Edge; Opera
(6) DISCLOSURE OF DATA
We will share Personal Data collected solely in the following events:
(i) we may share your information in order to comply with any applicable law, legal process or governmental request as well as for the purpose of enforcing our agreements and policies, establish, exercise or defend our rights and third party’s rights, and any applicable needed action in this regard. In addition, we may share your information to prevent or detect illegal activities, wrongdoing, and suspected fraud.
(ii) We may disclose Personal Data to our service providers so that they can perform requested services on our behalf. We prohibit such Service Providers from using your Personal Data for any purposes.
(iii) We may share your information to third parties when you provide your consent to a particular disclosure. However, if we do share your information based on your consent, following such disclosure, the information shared will be subject to such third party’s privacy practices which might differ from our practices detailed herein.
(iv) We may share your information with a parent company, subsidiaries, joint ventures, or other companies under common control (“Affiliated Companies“) solely if and when applicable or necessary. In addition, we may share information, in the event of a corporate transaction (e.g. sale, merger, consolidation, etc.), provided however, that our Affiliated Companies or acquiring company will be subject to the obligations detailed herein with respect to your Personal Data;
(v) We may share IPs collected by us (as detailed above), for the purpose of operating and improving our business, providing the Services and remarketing, as well as to detect fraud, security or technical issues in connection with the Site.
We may share the Non-Personal Data as well asuse, disclose or transfer aggregated and processed data to third parties for any purpose we find applicable to our business operation.
(7) DATA RETENTION
We retain the data we collect solely for as long as required to fulfil the purposes for which it was initially collected, or for longer periods in the event we are required to do so in order to comply with legal, tax and accounting requirements. In addition, we will retain information we believe is needed in order to protect our rights and interests, in accordance with applicable laws.
(8) DATA SECURITY
We employ security measures to protect your data from unauthorized access, use, disclose or accidental loss and destruction. For more information regarding our security practices, please review our Information Security Policy. Note that, 100% security can never be provided, thus we will not be responsible for unauthorized acts that are beyond our control. In the event of a data incident relate to your Personal Data, we will take reasonable efforts to provide notification (in the event required under applicable laws).
(9) THIRD PARTY CONTENT AND SITES
This Website includes links to websites and services not owned or operated by us and which their privacy practices may differ from ours. We are not and will not be held responsible to such third parties’ privacy practices once you leave our Website.
(10) USER’S RIGHTS AND OPT OUT CONTROLS
Privacy laws in your jurisdiction may provide you with different rights regarding your Personal Data, such as; (i) the right to access your Personal Data; (ii) the right of rectification of your Personal Data; (iii) the right to have your Personal Data erased (as long as we do not have a legitimate reason for retaining the data); (iv) the right to restrict processing of your Personal Data; (v) the right to object to processing of your Personal Data; (vi) the right of data portability; (vii) the right to file a complaint to a supervisory authority in your jurisdiction; and, (viii) the right to withdraw consent (if applicable).
If you wish to exercise your right regarding your Personal Data, or you wish to be provided with more information in this regard, or if you have any concerns or complaints regarding your privacy rights, please contact us at: firstname.lastname@example.org.
In addition, we provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data. For more information, please review our Data Subject Right Policy.Further, if you wish to exercise any or all of the above rights, please download our applicable form and send it to: email@example.com.
Note that, we will require certain information from you in order to verify your identity and locate your data. Such process may take reasonable time, however not more than one (1) month, unless otherwise required or permitted under applicable law.
Notwithstanding the above, you have the right to contact your local data protection authority, at any time.
Further, you may opt-out of the data collection related to our Website, as follows:
(i) you may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set, by adjusting the privacy and security settings of your web browser. In these regards, please see the links provided under the Cookies Sectionof this Policy.
(ii) you may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website-NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website- DAA opt-out page
(iii) you may contact us (as detailed below), and we will make best efforts to assist you;
(11) CHILDREN’S PRIVACY
Our Services are not directed or intended for children, as defined under applicable law (i.e., thirteen (13) years of age if you are located in the US, sixteen (16) years of age if you are located in the EU or as otherwise defined under applicable laws in your jurisdiction). We do not knowingly collect or solicit information from children. If we later obtain actual knowledge that a user is considered as a child, we will take steps to immediately delete its Personal Data. We request that such individuals do not provide Personal Data through the Services. If you are under 18, please be sure to read the terms of this Policy with your responsible adult.
(12) TRANSFER OF DATA
We may store or process your information in the United States, EU or in other countries. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA.
(13) DO NOT TRACK DISCLOSURE
This Website does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.
(14) CONTACT US
If you wish to be provided with any other information related to our privacy practices, or you have any questions or concerns, please contact us at:
(15) DATA PROTECTION OFFICER
If you have any requests regarding the data collected under this Policy, including without limitation, requests to exercise your rights regarding your Personal Data that we hold, please contact our Data Protection Officer: firstname.lastname@example.org
Please include your name and contact details (email or address) in order for us to be able to respond.