Last Revised: February 5, 2018
ComboTag Technologies Ltd. (“us“, “we” or “Company“) respect the privacy of our users (each, “you” or “User“) and are committed to protect the privacy of Users who access, visit, use or engage with our website(s) or any other online services we provide via our analytics technology services which our clients use on their websites, or on websites where our clients have permission to use our online services, or on websites where our clients have programmatic access to thereof (collectively: the “Services“).
- What type of information we collect
- Cookies and other technologies
- How we use the information
- With whom we share the information and for what purpose
- For how long we retain the information
- How we protect your information
- Advertising ID and Advertising Identifier
- How to contact us
What type of information we collect
We may collect two types of data and information from our Users.
The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services (“Non-personal Information“). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information“). Such information may include:
- Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself.
- Voluntarily Information: We may collect information which you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports which you send to us. Please note that we may also collect complaints about you from other Users, which may include your Personal Information.
- Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) as well as other information which relates to your activity through the Services.
For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
Cookies and other technologies
A “cookie” is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother.
Our website(s) may use the following types of cookies:
- Session Cookies which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.
You may remove the cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Services may not operate properly and your online experience may be limited.
How we use the information
- To set up your account and to provide our Services (e.g., to provide analytics which allow websites, app developers, advertisers and third-party ad platforms to better understand the effectiveness of their various content);
- To identify and authenticate your access to certain features of the Services;
- To communicate with you and to keep you informed of our latest updates;
- To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests;
- To support and troubleshoot the Services and to respond to your queries;
- To investigate and resolve disputes in connection with your use of the Services;
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
With whom we share the information and for what purpose
We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers; (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the company.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.
Third-party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them.
For how long we retain the information
We respect your privacy rights and therefore you may contact us at any time and request: (i) to access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); or (ii) that we will cease any further use of your Personal Information (for example, you may ask that we will stop using or sharing your Personal Information with third-parties) or that we shall remove your Personal Information (subject to any other legal obligation that may require us to keep the information).
Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements. Without derogating from the foregoing, in any other case we will retain the information for a maximum period of three years.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at email@example.com.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.
How we protect your information
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at firstname.lastname@example.org.
We may also use our third-parties and share with them Users’ information to assist us in evaluating the success of our advertising campaigns and help us retargeting our Users.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
The Services are not designated to individuals under the age of 16. If you are under 16 years old, you should not use the Services, or provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that an individual under the age of 16 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at email@example.com.
Advertising ID and Advertising Identifier
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. We may also use Apple’s Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple, and any information obtained through the use of the Advertising Identifier, for the purpose of advertising.
By using the Services you explicitly agree that we may associate your Advertising ID and your Advertising Identifier with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID or Advertising Identifier respectively, we will use other identifiers.
How to contact us
If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at firstname.lastname@example.org.
Information about us
The details of the Company are as follows:
ComboTag Technologies Ltd.
Rothschild 37 St. Tel Aviv, Israel