PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
As required under the CCPA, we will update this Privacy Notice every 12 months. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Notice.
TYPES OF PERSONAL INFORMATION WE COLLECT
Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and has collected within the last 12 months), are detailed in the table below.
Please note that, under the CCPA Personal Information does not include: publicly available information from government records and deidentified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).
|A. Identifiers.||A 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.||Yes
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes
|G. Geolocation data.||Physical location or movements.||Yes|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows: (i) directly from you, for example, if you contact us or where you voluntarily provide Personal Information while you interact with a Content Unit; (ii) indirectly from you, for example, from observing your actions on our website; (iii) from third-party business partners such as analytics providers.
USE OF PERSONAL INFORMATION
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry.
- To provide, support, personalize, and develop our website and Services, as well as improve our Services.
- For security and fraud detection purposes, and to maintain the safety, security, and integrity of our Services.
- For testing, research, analysis, and product development, including to develop and improve our Services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As a Service Provider, we may disclose your Personal Information to a third party for a business purpose, on behalf of our Business Partners. In addition, we may share our website’s Visitors and Business Partners Personal Information for a business purpose (such as email marketing on our behalf).
We share your Personal Information with the following categories of third parties:
- Service providers
- Data aggregators
- Business Partners
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:
Category A: Identifiers.
Category F: Internet or other similar network activity.
Category K: Inferences drawn from other personal information.
SALES OF PERSONAL INFORMATION
In the preceding twelve (12) months, Company has not sold Personal Information.
Note that, as we are considered as the Service Provider of our Business Partners, in the event you are an end user interacting with a Content Unit or an Ad, the Business Partner may provide you with a “Do Not Sell” link.
You may also use industry opt-out mechanisms, for example:
Digital Advertising Alliance (“DAA”) Opt-Out
The DAA offers tools to provide consumers with choices as to whether participating third parties can use your information to provide targeted advertising. To learn more about interest-based advertising, please visit the DAA http://optout.aboutads.info/?c=2&lang=en. To opt out of sharing your information with such participating third parties for targeted advertising, please use the following tools:
- For websites:
the DAA WebChoices Tool, available at http://optout.aboutads.info/?c=2&lang=EN.
- For mobile applications:
the DAA AppChoices Tool, available at http://www.aboutads.info/appchoices.
Network Advertising Initiative’s (“NAI”) Opt-Out
You may opt out of Google Analytics by installing Google’s opt-out browser add-on, and opt out of interest-based Google ads using Google’s Ads Settings. Google may also participate in the DAA WebChoices Tool (above).
- The opt-outs described above are device and browser based. you must opt out on each device and each browser where you want your choice to apply.
- Opt-outs may be stored via cookies. If you clear cookies, your opt-out will no longer be valid and you must opt out again where you want your choices to apply.
- We do not maintain or control the opt-out mechanisms and settings above and not responsible for their operation.
- Exercising these choices does not prevent from delivering contextual advertising or using information for non-targeted advertising purposes. Furthermore, we may also still share some Personal Information for a business purpose.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
The CCPA provides consumers with specific rights regarding their Personal Information. Please review our Privacy Rights Policy regarding your rights under applicable law.
You may exercise any or all of your above rights in relation to your Personal Information by filling out the Privacy Rights Request (“PRR”) form available here
and send it to our privacy team at: email@example.com.
If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us:
- By sending an email to our Data Protection Officer at: firstname.lastname@example.org
- By mail at:
3 Soncino St.
Tel Aviv, Israel 6721603
- Facsimile copies can be sent to the following number: +972-795599812, however we do encourage you to reach out via email which is checked more often.