Privacy Policy - PromotionTailor

Date May 2018

This privacy policy (the "Privacy Policy") is an integral part of the terms of use and both documents should be read together.

The Operator respects the privacy of its users. In order to improve the protection of the Users, the Operator publishes this Privacy Policy regarding how the Operator collects Your information from Your use of the Website.

The processing and collection of personal data is governed by the Israeli law and by the General Data Protection Regulation (the “GDPR”), and whenever you’ll provide the Operator such information, the Operator will only use your information in line with all applicable data protection laws, including the GDPR. At all times You are in control of Your information, and You can withdraw Your consent to provide Your information to the Operator.

The data controller of the Website is E.M Platform Ltd, Israeli Company No. 515278661 (the “Operator") which is the entity which decides how Your personal information is processed and for what purposes as detailed in the Privacy Policy.

1.    General

During Your use of the Website, the following information about You will be collected:

·         Upon registration – Name, email address, sex, state, date of birth;

·         Statistics regarding Your use of the Website (see Section 7.2 of this Privacy Policy regarding web analytics cookies).

 

 

2.    Your Rights Regarding Your Personal Information

2.1.  Under the GDPR and subject to different exemptions, You have the following rights:

·         To access Your personal data and receive a copy of Your personal data upon Your request;

·         To rectificy, erase or restrict Your information upon Your request (right to be forgotten);

·         To object to the processing of Your information;

·         To request that the Operator will provide the You with Your personal information and, if possible, to transmit Your data directly to another data controller (right to data portability).

·         To withdraw Your consent to processing and the processing at any time;

2.2.  No fees are required for exercising any of the above rights. However and subject to the GDPR, the Operator may charge You a reasonable fee including administration fees if Your request is repetitive or excessive or demands the Operator to bear excessive and/or expensive efforts.

2.3.  To exercise your rights, please contact the Operator’s Data Protection Officer at the following contact details:

Data Protection Office

E.M Platform Ltd

31 Olei Hagardom St.

Tel Aviv 6986048

Israel

gdpr@promotiontailor.com

3.    Database and Use of Information

3.1.  All collected information as stated above is stored in the Operator’s database. With accordance to Your consent, the Operator warrants to use such information for the following purposes:

·         Enabling convenient and efficient use and providing you the Operator’s Services;

·         Improve and enrich existing services and content;

·         Modify and/or remove existing services and content;

·         Enforce the Operator’s Terms;

·         Providing You unique services including sending you newsletters upon providing Your email address;

·         Any other purpose detailed in the Terms and this Privacy Policy.

Your information is collected and used because the Operator has a legitimate business interest for Your personal data to be used for the above purposes. This enables the Operator to send You relevant and personalized content designed to improve Your use of the Website. You have the right to object to this by contacting the Operator via email: gdpr@promotiontailor.com. Please note that if you object, this may affect the Operator’s ability to send personalized content to You.

3.2.  Please note that some of the information You will be requested to provide is necessary for providing You the Services. Therefore Your refusal to provide some information may result in You not receiving the Services since the Operator will not be practically able to provide you the Services.

3.3.  The Operator may receive Your information from third parties which the Operator cooperates with (e.g. business partners, professional advisors, service providers, etc.) and the Operator may receive Your information from them.

4.    Transferring Information to Third Parties

Subject to Your consent, the Operator may transfer and/or share Your information in the following events and circumstances and, when applicable, will give you reasonable notice upon doing so:

·         When You have permitted the Operator to transfer and/or share Your information, and in such case the Operator will always ensure that Your information will remain protected and secure when being transferred;

·         When You violate the Terms of the Website or act illegally;

·         To enforce the Terms or the Privacy Policy;

·         In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency;

·         To establish or exercise the Operator’s legal rights;

·         To defend against legal claims; or as otherwise required by law. In such cases, the Operator may raise or waive any legal objection or right available to the Operator, in the Operator's sole discretion;

·         To protect and defend the rights, property or safety of the Operator, its Users, employees or others;

·         In connection with a substantial corporate transaction, such as the sale of the Operator’s business, a divestiture, merger, consolidation, or asset sale, or in the event of liquidation.

5.    Third-Parties

5.1.  There are a number of places on the Website where You may click on a link to access other websites that do not operate under this Privacy Policy and are not related to the Operator including, but not only, links leading to Third Party Websites. These links may independently solicit and collect information, including personal information, from You and, in some instances, provide the Operator with information about Your activities on those links.

5.2.  Every third party such as detailed above may have its own privacy policy describing its use of personal information, and such policy will regulate the use, handling and disclosure of such personal information of the User. Should You require additional information regarding any privacy policy of third parties, The Operator recommends that You visit these third-party websites and read their privacy policies. It is clarified that such third parties, unless explicitly mentioned otherwise, are neither controlled nor owned by the Operator.

5.3.  Your information will be handled and used by the Operator’s trusted third parties including the following recipients in order to deliver services provided by the Operator:

·         Analytics and search engine providers that assist the Operator in improving the optimization and performance of the Website;

·         Email delivery-service providers.

6.    Retaining Your Information

6.1.  The Operator will only retain Your personal information for as long as necessary to fulfil the purposes it was collected for including, but not only, for the purposes of complying with legal, accounting, or reporting requirements. The retention period is determined based on the amount, nature, and sensitivity of Your personal information, the potential risk of harm from unauthorized use or disclosure of Your information, the purposes for which the Operator processes Your information and whether such purposes can be achieved through other means with accordance to any applicable law.

6.2.  Statistical information regarding Your use of the Website will be retained for a period of one (1) year, thereafter such information will be removed from the Operator’s systems.

6.3.  Information regarding Your session use of the Website will be retained for a period of one (1) hour, thereafter such information will be removed from the Operator’s systems.

6.4.  Your details for marketing communications will be retained until You will address the Operator and request that You no longer wish to receive marketing messages from the Operator.

7.    Use of Cookies

7.1.  Upon Your consent, the Operator uses various technologies to collect information from Your device and about Your activities while using the Website in order to improve and personalize Your online experience of the Website including by means of storing cookies to Your device. Please note that some of the cookies the Operator uses are necessary for using the Website and some cookies are used to provide features of third parties.

7.2.  The Operator uses the following cookies:

·         Necessary Cookies which are essential for providing services of the Website. These cookies do not record any of Your identifiable personal information and the Operator does not need Your consent to place these cookies on Your device. Please note that without these cookies, The Operator will not be able to provide You some of the services offered by the Operator.

·         Functionality cookies which are used to remember Your settings to enhance Your visit of the Website (e.g. text size, language, time zone or other preferences). The information these cookies collect is anonymous and does not enable the Operator to track Your browsing activity on the Website By using the Website You agree that the Operator can place such cookies on Your device. Please note that at any time You have the right to withdraw Your consent and object from being remembered by the Website.

·         Web analytics cookies which are used to collect information about how You use and navigate the Website so that the Operator will be able to add new features and improve Your of the Website. This information is anonymous and cannot be used to identify you personally. Please note that at any time You have the right to withdraw Your consent and object from this.

7.3.  Please note that if You choose to disable some or all of the above cookies, the Operator cannot guarantee the proper performance and use of the Website and some features may not function properly.

7.4.  During your use of the Website, third-party websites may store cookies to Your device, e.g. when some content of the website is embedded from the Third Party Websites. Please note that the Operator has no control over these cookies and You should check such third party’s cookie policy.

8.    Data Security

8.1.  The Operator takes appropriate security measures for data security purposes to help prevent unauthorized persons from gaining access to Your personal information. However, no system can be completely secure. Therefore the Operator does not warrant that its services will be totally immune to any breaches of security and/or unauthorized access, including access to the data stored in the Website, although the Operator will contact You upon a breach of Your data security with accordance to any applicable law.

8.2.  The Operator inspects, from time to time, the data security of the Website and performs modifications and upgrades accordingly in order to keep the Website’s security. Nonetheless, the Operator will not be liable for any direct or indirect damage caused to You due to exposure of Your information by an unauthorized access to the Operator’s database and/or due to any negligence or act not controlled by the Operator.

 

9.    Email Updates

9.1.  The Operator may offer to all its users to receive email messages and/or newsletters about updates, improvements and other user notifications regarding the Operator’s activity, including via emails and SMS (the “Mailings”).

9.2.  It is clarified that at any stage You will have the ability to opt out of receiving the Mailings by contacting the Operator and/or by clicking on a link available on the Mailings sent to You by the Operator.

 

10.  Changes to This Privacy Policy

The Operator may occasionally update this Privacy Policy. The Operator will notify You by sending an email to the email address You most recently provided the Operator and/or by prominently posting notice of the changes and will state at the heading of the Privacy Policy the date of change.

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