PRIVACY POLICY – PRO MOBITECH
Last updated: Dec 01, 2019
This Privacy Policy (this “Policy”) describes Pro Mobitech Technologies’ (“Mobitech”, “Company”, “we”, “us” or “our”) data collection and protection practices. The Policy applies to data collection, treatment and use of users, whether our publisher customers or their end users,(collectively, “Users”) that consume or access the Mobitech platform (the “Platform”).
When used in this Policy, the term ‘Platform’ means to include any related websites, applications, programs, widgets, features, components (the “Mobitech Solutions” or “Services”).
If you use the Platform, or access to the Services, it means that you visit a website or application that integrates our Platform (“Hosting App”). Hosting Apps will have their own privacy policy and standards, and will be available to you directly by them when you first access or install them.
Before you use the Platform and Services, please be aware and confirm:
1. We do not collect any personally identifiable information of end users. We do collect data that in some jurisdictions may be considered as personal information (such as an IP address), but we never use it in a way that allow to personally identify a person.
2. Your use of the Platform in any form of engagement constitute you consent and acceptance of this Policy. Otherwise, you may not engage with the Platform and the Services that we provide.
3. Data controller details:
Pro Mobitech Ltd.
B.S.R 1 Tower, Ramat Gan, Israel
For convenience and ease the understanding of this Policy, we will refer to our publisher customers as “Customers” and to their app’s or website’s visitors, as End Users.
1. CUSTOMER INFORMATION
a. Collection of Customer Information
If you are a Customer of our Services, we may collect information that can be used on its own or with other information to identify or contact you as a natural person (“Personally Identifiable Information” or “PII”). To this extent, you will be asked to provide your first and last name, your email address or the email address of the entity on which behalf you are engaging us and the password you choose for accessing your account with our Platform. Such information is mostly used for our customer relation purposes and will always be provided voluntarily by our Customer. We will collect any information or content that Customers provide us (collectively “Customer Information”).
b. Our Use of Customer Information
We use Customer Information in order to (i) render our services and contact Customers that express their will to communicate with us and engage with the services; (ii) communicate with Customers and respond to any inquiry or any other form of communications from Customers; (iii) Provide access to service providers, agents, contractors, vendors and other individuals or entities which require Customer Information in order to perform their functions.
c. Sharing Customer Information
We may disclose or share Customer Information to a current or future (i) affiliate, parent companies and/or subsidiaries that help us with facilitating the Services or operating our websites; (ii) service providers, agents, contractors, vendors and any other individual or entity which requires access to Customer Information in order to perform their functions; (iii) other Customers, to the extent required to render the Services and consented by Customer; (iv) Service providers and CRM platform that are designed to facilitate customer relation operation.
d. Rights and Choices
As our Customer, you have certain rights concerning your Customer Information, including: edit, correct, verify, update or delete your Customer Information. If may exercise your rights, by contacting us directly at: [email protected].
2. END USER INFORMATION.
a. Collection of end User information:
· Non-Personal Information (“non-PI”): We may collect information that by no means can lead or being used to identifying an individual person and includes: your browser type, language, version, user agents (that include your device and operating system types and versions, mobile carrier and other technical data about the operator). We may also gather statistical information about Users’ interaction with the Platform and related features, buttons, functionalities, links, ads.
· Device and Browser Information: We also collect end User’s browser’s requests information, statistics on page views and standard web log information, categorization of some of the web pages that the User has visited, icons or fields that the User has clicked on, search sites that the User accessed and/or some of User’s general search activities, like common search keywords used by users; such information is normally automatically transmitted in HTTP request from your browser to our servers. As part of facilitating the Platform and Services we may gather additional information such as the User’s location and relevant User content categories. That way, User’s future search activities will be influenced by User’s previous search and interests.
· Personal Information: We may collect Users’ advertising ID that was allocate to your device by the operating system, as well as IP address, for purposes of identifying language and general geographic location, for purposes of device validation (user/non-user) and fraud prevention. In some jurisdictions, and given the circumstances and type of use, IP address may be considered as a personally identifiable information. However, we makes no use of the IP address to attempt and reveal your identity, nor act in any way, including to combine sources of information in order to reveal your identity. If you reach out to us by email or any other channel and provide us with your Personal Information (such as email address, full name or any other information), we may collect those details for purposes of addressing your request.
b. How We Collect User Information
We use tracking technologies for web and mobile apps, such as cookies (web) and advertising ID (mobile apps):
· Cookies: A cookie is a small text file that is placed on the browser of the hard drive of your computer (or similar device) by websites that you visit (“Cookie”). Most websites and online services use Cookies, which are typically used (together with web beacons) in order to make websites or web services function, or function more efficiently, as well as to provide information to the owners of the particular website or service. Cookies make your use of the Services easier to use and improve their functionality. Additionally, is some of the Mobitech Technologies we operate, Cookies are essential for the proper functionality of that Mobitech Solution that are available by it. Most browsers are automatically set to accept cookies, but you can usually modify your browser settings to disable cookies or to completely remove them. If you choose to disable cookies though, you may not be able to use certain features and services.
· Web Beacons: We, or advertisers partners, may use standard Internet technology such as web beacons (or "clear gifs"), tracking pixels, and other similar technologies, to gather analytics, anonymous, aggregate, non-personally identifiable information about Users that interact with the Mobitech Solutions. Please be noted that we may host third party content, features, elements and services that are not necessarily provided by us (“Third Party Content”). Such Third Party Content may include graphics, animation, video, ads, offers, links, buttons or any their similar feature with which you may engage. Any interaction you make with such Third Party Feature is govern by their providers’ policies, terms and conditions, so we advise you to refer to their privacy policies to learn more about their data collection and protection practices.
· Log Files: Technical information from your browser is automatically collected into a log file, when a you interact with any of the Mobitech Solutions.
· Advertising ID (android) / ADID (iOS): is an “identifier” that is generated by your mobile operating for advertising purposes. It is unique but random and can easily be re-generated upon your choice.
c. How We Use End User Information
The information that the we collect is used for the Services provisioning. We learn from the User Information what end Users want, like, dislike or commonly search, and we help to make it more accessible and relevant for them. We also use the User Information to extract aggregations and statistics over time, so we can keep our Services and products relevant, current and actual. In addition, such information (specifically engagement and interaction with the Mobitech Solutions) helps us to (i) better understands trends, interests, thus shape up our solutions and related content; (ii) report level of engagement to content creators and providers and this ability to track and bill; (iii) information like advertising ID enables us to improve and customized the Mobitech Solution’s so as to enable and facilitate Users’ opt out options should they decide to not use the Mobitech Solution.
In additions, when collected as part of the Mobitech Search Solution, the information that we collect is additionally used in order to suggest and adjusts Trending Keywords (as defined below) and make such keywords and advertisements served through the Mobitech Search Solution more personalized and relevant. “Trending Keywords” means the suggestion of keywords which the Company deems relevant to User.
3. CHOICES AND OPT OUT
You can choose to opt-out from any given Mobitech Solution, and respectively, the collection of information by us with respect to the Mobitech Solution via the settings screen, available from the Mobitech Solution’ functionality. Further, if you do not wish your Personal Information to be collected, processed or shared for the above purposes or any other purpose, you may request to delete your information by sending an email to [email protected].
Please be noted that even if you have chosen to opt out from one of Mobitech Solution, one or more of the applications or websites you use may include the same or another Mobitech Solution. Any opt out option that you exercised applies only to the specific Mobitech Solution in the specific Hosting App from which you opted out.
With respect to the Mobitech Search Solution: you can choose to opt out from Trending Keywords personalization by utilizing one of the following:
· From a search result page: you can click on the settings icon, and it will lead you to a one-click opt out option in case you want to opt out completely from “trending keywords” personalization.
· From a search result page: you can click on the settings icon, and it will lead you to a list of trending keywords, clicking each keyword will remove it from current and future trending keywords suggestions.
· By opt-out from advertisement personalization in the Google Advertising Settings screen (read more here)
· By switching off the switch button next to the “Trending keywords” headers in the App/SDK or in the App/SDK settings screen.
· By long clicking a trending keyword in the appropriate trending keywords placeholder in the app.
Third party service or content providers, who assist us in operating and distributing the Mobitech Solutions and carrying out our business operations (“Third Party Vendors”), may also collect information in order to process and provide their services.
Such Third Party Vendors may include cloud computing services (like Amazon Web Services), and providers of monitoring and categorizing services. In addition to third party service providers, we may also use third party search providers or sponsored content providers to operate the Mobitech Solutions. Such Third Parties may also use cookies, JavaScript, web beacons (also known as action tags or single-pixel gifs), tracking technologies and other technologies, intended among others, to measure the effectiveness of their services or content and to personalize such content (including advertising and other sponsored content). We are not responsible for the privacy practices of such Third Parties, and you are encouraged to contact such Third Party Vendors directly to learn about their privacy practices, where they are made available to you (either via the Hosting App, the Mobitech Solution, the content that is available via which or this Policy).
When using the Mobitech Search Solution, be noted that one of the our third party content providers of is Microsoft Bing (“Bing“). Information concerning Bing’s practices is available at [privacy.microsoft.com/en-us/privacystatement/].
5. SHARING INFORMATION WITH THIRD PARTIES
We do not rent, sell, or share your Personal Information with any person or entity for marketing purposes (including direct marketing purposes), without your permission, other than as set forth in this Policy. Non-PI may be provided to other parties for marketing, advertising, services improvement or other uses.
We may share any information (i) to comply with applicable law, to respond to legal requirements and to enforce our policies; (ii) to respond to claims that any keywords or any other content violate the rights of others, to protect anyone’s rights, property, security or safety; (iii) to protect our, our agents’, affiliates’, distributors’, partners’ or our Users’ legal rights (including enforcement of agreements that we have interest in) or property, the our employees or employees of affiliated companies, agents and contractors; (iv) as part of any business operations with third parties that provide services (such as data analytics services, or performance analysis and tracking services) to us; or (iv) to protect against fraud or carry out risk management procedures. Such information will be disclosed in accordance with applicable laws and regulations.
We may share non-PI for marketing, advertising and customizing the Mobitech Solution and respective services.
In case where we go through a business transition such as a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, Customer and User information may be among the assets transferred.
We follow generally accepted standards, virtually and physically, to protect the Personal Information submitted to us, both during transmission, processing and retention. However, you should be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee at all times our data’s absolute security. If you have any questions about security with respect to the Mobitech Solutions or any of our software, you can contact the Company at [email protected]. Notwithstanding the foregoing, we shall not bear any liability for any unintentional disclosure or a disclosure that occurs due to a security breach of our systems or facilities.
We will retain and use the Personal Information for as long as needed to provide its services and as necessary to comply with our legal obligations and enforce our agreements.
With respect to the Mobitech Search Solution, we implement responsible measures in order to block inappropriate Trending Keywords, such as adult content, racism, harassment, terror, and other content that we or the Software’s owner may find inappropriate. You acknowledge that, since the filtering mechanism is statistically based, we cannot assure 100% protection. In any case you detect inappropriate keywords, you are requested to contact our support team at [email protected].
7. INTERNATIONAL TRANSFER OF DATA
We may transfer Information to other countries whose privacy laws may not be as protective as in your place of residence. By using r accessing the Platform and Services, you consent to the transfer of your Personal Information to other countries for processing consistent with this Policy, as well as to subsequent transfers of such information consistent with the other terms of this Policy.
EU Users information – should we transfer any EU Users Personal Information outside the EEA, it will ensure, among others by contractual commitments, to provide the Personal Information with the same level of protection required under applicable EU data protection laws.
8. USER RIGHTS, CONTROL AND CHOICES
Users (both Customers and End Users) have certain rights concerning their information. Our Users may decide at any time to exercise their rights with respect to their Personal Information, as follows:
· Customers: you may request to edit, update or completely delete any personally identifiable information about you if you are no longer want us to use it for the purposes you submitted to us.
· End Users: as we do not retain or process any personally identifiable information about end Users, we cannot process request for edit or deletion, however, we do grant End Users ability to opt out or delete identifiers of their machine or browsers, such as cookies, tags, and Advertising ID/ADID, as described in this Policy and also available via the settings of the operating system/browser.
For additional information on how can Users (Customers/End Users) exercise these rights you may contact us by sending an email to [email protected] or sending a paper letter to our Privacy Officer at the following address: B.S.R 1 Tower, Ramat Gan, Israel.
9. CHILDREN’S PRIVACY.
We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register. If you are between the age of 13 and 17, you are requested to use our services with adult supervision only. If you are under the age of 13, you are requested not to send us any Personal Information. If we learn that it we have collected Personal Information from a User under age 13, we will remove that information as quickly as we become aware of it. If you believe that we might contain any Personal Information from or about a User under the age of 13, you are requested to contact us at the contact information below.
10. CONTACT US
If you have any questions about this Privacy Policy, you are requested to contact us at [email protected], contact person: Gal.
Or send a letter to: B.S.R 1 Tower, Ramat Gan, Israel
11. CHANGES TO THIS POLICY
We may modify information presented via the Mobitech Solutions and/or this Policy from time to time. If we make any material changes, we will notify you by posting a notice on our website prior to the change becoming effective. You should check back here periodically to see if this Policy has been updated. We will always show the date of the latest modification of this Policy at the bottom of the page so you can tell when it was last revised.
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APPLICABLE TO THE MOBITECH SEARCH SOLUTION
The Mobitech Search Solution includes a “Trending Keywords” feature, which can be used by Users or Hosting Apps via an API and/or SDK and/or stand-alone software application.
The “Trending Keywords” feature enable us to provide Users with personalized trending keywords results, as our algorithm takes into consideration parameters such as Users’ search activities, interests and more, as set forth herein.
When a User uses the “Trending Keywords” feature for the first time, the Mobitech Search Solution will suggest various organic keywords, such as words suggested based on trending searches, localized and global news. Over time, the Trending Keywords feature will be derived according to User’s actions and/or signals, taking into account parameters such as previous search terms used in the Mobitech Search Solution, user’s online shopping history, User content category, as set forth herein. The Trending Keywords feature would be semantically related to the User’s actions and/or signals. For any questions regarding the suggested keyword, please contact our support team at [email protected].
APPLICABLE TO THE MOBITECH CONTENT SOLUTION
The Mobitech Content Solution includes content personalization feature, meaning that we and our content providers will try to match content according to users preferences.
The content personalization is done according to users’ engagement with the content that is presented to them. The personalization is subject to section 4 in this Privacy Policy (User choices to opt out).
Mobitech uses third party content providers in order to aggregate content which is relevant to the users. Mobitech comply with the third party content providers' privacy policy.
To read further about the third party providers Privacy Policy, please read further in the following links:
· https://www.outbrain.com/what-is/
· https://www.taboola.com/privacy-policy
· https://www.outbrain.com/legal/privacy#privacy-policy
· https://www.mgid.com/privacy-policy
· https://www.youappi.com/privacy-policy/
HQ Address: 2 Derech Ben Gurion st. B.S.R 1 tower, Ramat Gan, 5257334. Tel: +972-36490805
This document was last updated on Dec 01, 2019