Apester is the developer and owner of the technology and platform (“Platform”) intended for: (i) owners or operators of websites, applications or other digital assets and services (“Digital Assets” and “Publishers” respectively). Apester enables the Publishers to create, embed and share within the Digital Assets interactive content units (“Content Unit”) including, but not limited, online quizzes, questionnaires, feedback applications or other features for the purpose of creating end user interaction; and (ii) for third party advertisers (“Advertisers”) to display advertisements and other promotional content (“Ads”) within such Content Unit ((i) and (ii) collectively shall be referred to as the “Services”). The Publishers and Advertisers shall be referred to collectively herein as “Business Partners”.
We collect and process certain information when visitors browse our website: www.apester.com (“Visitors”),we collect and use certain information about Business Partners using our Platform and Services or on behalf of our Business Partners, such as information on the end users, the individuals watching the ads or interacting with the Content Units, as applicable the “end users”, “Visitors” and “Business Partners” collectively shall be referred to as “you”).
This Policy applies to all information about you that we collect in connection with the Services throughout the world, and explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data (as defined below) under the applicable privacy laws such as the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).
In the event you are a California resident, and the CCPA applies to you – please review our CCPA Privacy Notice.
CONTACT INFORMATION AND DATA PROCESSOR INFORMATION:
Apester Ltd. incorporated under the laws of Israel, and it is the processor of your Personal Data.
You may contact us and our privacy team as follows:
- By Email: firstname.lastname@example.org.
- By Mail: Apester Ltd., Hamasger St 64, Tel Aviv, Israel 6721712
DPO Contact Information: email@example.com
DPR Contact Information: Prighter
UK DPR Contact Information: Prighter
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights (in the UK & EU), please visit the following website: https://prighter.com/q/16601885426
DATA SETS WE COLLECT AND FOR WHAT PURPOSE:
You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.
During your interaction with our Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data“). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc.
We may also collect from you, during your access or interaction with the Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data” or “Personal Information”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below. For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).
The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:
|Online Identifiers: |
Agent, unique ID, Cookie ID, IP, and other online unique identifier.
|We process such data when you visit our website through third party cookies for analytic and remarketing purposes.||Consent which we will obtain through our cookie notice. You may withdraw consent at any time by using the cookie preference settings with Apester, adding/ removing consent to Apester.com.|
|Information Provided Voluntarily: |
If you voluntarily contact us for your interest in our products, support or other inquiries, you may be required to provide us with certain information such as your name, company name and domain, monthly impressions, email address, and any additional information you decide to share with us. Furthermore, if you use our live chat feature, you may be sharing additional information with the representative assisting you through the chat.
|We will use this data to provide the support you requested or respond to your inquiry.||We process such contact information subject to our legitimate interest in order to respond to your inquiry.|
In the event you sign up to receive our newsletter or other marketing materials, you will be requested to provide your contact details, such as your email address.
|We will use your email in order to send you our newsletter and other marketing materials.||We process such contact information subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email or by contacting us directly.|
In the event you apply for a job via our website, we will process your CV (and the information included therein), your cover letter as well as additional information you decide to provide such as your contact information (name, email and phone number).
|We will use this information to process your job application and for recruitment purposes.||We process such information subject to our legitimate interest.|
|White Paper and Case Studies: |
In order to download the case study available on the website you will be required to provide contact information such as name, email address, and company name.
|We will use this information to provide you with the whitepaper. We will also use the email address to follow up with your interests and suggest our services (“Direct Marketing”).||We process the contact information subject to contract necessity
Direct Marketing is subject to our legitimate interest.
|Request a Demo: |
When you contact us and request a demo we will need to request certain information such as you name, email, phone number and your goals and purposes in using the Services.
|We will use this information to enable you to use our platform. |
We process such information subject to our legitimate interest.
|We process such information subject to our legitimate interest.|
|Business Partner’s Registration If you are or wish to become a Business Partner, or otherwise wish to be provided with the ability to use our demo, you may be required to provide us with certain information such as: your full name, email address, phone number and country. Additionally, during the registration process you will be required to create a username and password.||Your contact details will be used in order to send you needed information related to our Services and our business engagement (e.g., send you a welcome message, notify you regarding any updates to our Services, send applicable invoices, etc.) and additional occasional communications and updates related to the Services, as well as promotional and marketing emails. We may also use the information in order to verify your identity.||We will use this data for the purpose of performing our contract with you, meaning, to provide the Services and to designate your account.|
|Log in Through Social Network:|
When you log in to our Services through your Facebook or Google account, we will process certain information such as your Facebook ID, name and may process information you made public.
|Your contact details will be used in order to send you needed information related to our Services. In addition, it will be used for additional occasional communications and updates related to the Services, as well as promotional and marketing emails.||We will use this data for the purpose of performing our contract with you, meaning provide you with our Services and designate your account.|
As a Business Partner, we will send you invoices, materials and marketing content through the email information you provided during your onboarding.
|We will use this information to keep you updated with offers and content such as updates, new capabilities and features, and to send you invoices and supporting documentation.||We process such information subject to our legitimate interest. You can opt-out at any time, however certain content (such as invoices) will still be sent.|
|End user interaction with ads and interactive Content Units: |
Apester will collect information from the end users interacting with the Content Units such as, session ID connected to surveys, quiz, or other interaction data.
We collect information provided by the end user voluntarily while interacting with the Content Units (for example, answers to a quiz or survey, personal information).
When ads are placed within the Content Units, we process and transfer online identifiers, such as IP address, UDID Cookie ID, TCF strings (we do not process cross device information).
This data is further used by Advertisers for the purpose of displaying personalized ads. .
|We use this data for the purpose of operating, providing, maintaining, protecting, managing, customizing and improving our Services and the way in which we offer them; (ii) enhancing your experience; and (iii) auditing and tracking usage statistics and traffic flow as well as calculate payments related to the Services, we provide to Business Partners.|
Where required under applicable law, we will require our Business Partner to request for your consent to collect such data for advertising purposes.
|Consent which we will obtain through our cookie notice. You may withdraw consent at any time by using the cookie preference settings, with Apester, adding / removing consent to Apester.com.|
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.
Please further be advised that, as an end user interacting with the Content Units, you might be subject to additional data collection directly on behalf of Business Partners (meaning the Publishers operating the Digital Assets in which our Content Units are implemented, as well as Advertisers providing the Ads displayed in the Content Units). We are not responsible, nor do we monitor such data collection, that shall be governed by such Business Partner privacy policies.
HOW WE COLLECT YOUR INFORMATION:
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:
- When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.
COOKIES AND SIMILAR TECHNOLOGIES:
Cookies we use on our website:
Cookies we use on our Platform:
We or our third party affiliates and Business Partners may use “Cookies” and similar tracking technologies for various purposes.
We place First Party Cookies on Partner’s digital assets; these cookies collect certain personal data from the end users related to interaction with Content Units as well as TCF strings.
Our Partners may independently collect, through the use of such tracking technologies, some or all types of Personal Data detailed above, including combining such information with other information they have independently collected relating to your browser’s activities across their network of websites, for enhanced targeting functionality and delivering personalized ads, as well as providing aggregated analytics related to the performance of the interacted campaign or advertisement. These third parties collect and use this information under their own privacy policies, and are responsible for their practices. You may also opt out of certain third party 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. Or the European Interactive Digital Advertising Alliance (“EDAA”) website Your Online Choices page.
Our Business Partners may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the Business Partner’s privacy policies. Please note, however, that we are not responsible for the privacy practices of our Business Partners, and other third parties.
DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
CATEGORY OF RECIPIENT
DATA THAT WILL BE SHARED
PURPOSE OF SHARING
|Advertisers||IP address, page URL, and Unified ID||We provide such information to our Business Partners, so they will be able to bid for content that best suits such a web-page, as a part of our Services. In some cases when we buy media online, we may submit non-personal information that is cookie based. In those cases, non-personal parameter we provide to the media owner may become personally identifiable when such a media owner combines our parameters with its own existing information about you.|
|Trusted Agents and Service Providers ||All data||We may disclose Personal Data to our trusted agents (such as legal counsel) and service providers (including, but not limited to, our Cloud Service Provider, Analytics Service Provider, CRM provider, etc.) so that they can perform the requested services on our behalf. Thus, we share your data with third party entities, for the purpose of storing such information on our behalf, or for other processing needs. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services|
|Any acquirer of our business||All data||We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.|
|Affiliated Companies||All Data||We may share aggregate or Non-Personal Data with our affiliated companies and additional third parties in accordance with the terms of this Policy. We may store any type of information on our servers or cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Services, aggregate statistics, marketing and conduct business and marketing analysis, and to enhance your experience.|
|Legal and law enforcement||Subject to law enforcement authority request.||We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.|
When we share information with services providers and Business Partners, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).
We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
USER RIGHTS AND OPT-OUT OPTIONS:
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination and the right to cease sharing or selling your information as such term is defined under the California Privacy Regulations such as the CCPA (as further detailed in the CCPA notice ).
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to opt out, where applicable.
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 Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry, such as encryption using SSL, we minimize the amount of data that we store on our servers, restricting access to Personal Data to Apester employees, contractors, and agents, etc.. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
INTERNATIONAL DATA TRANSFER:
Our data servers in which we host and store the information are located in the US. The Company’s HQ are based in Israel in which we may access the information stored on such servers or other systems such as the Company’s ERP, CRM, Salesforce, and other systems. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area (“EEA“) is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Information, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes.
ELIGIBILITY AND CHILDREN PRIVACY:
The Services are not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a “child” immediately upon discovering that such a user shared information with us. Please contact us at: firstname.lastname@example.org if you have reason to believe that a child has shared any information with us.