Wazimo Media Ltd. d/b/a, inter alia, (“Wazimo” or “we”) respects the privacy of its Site's users (“User” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our content website at Wazimo (the “Site”). Please read the following carefully to understand Wazimo’s views and practices regarding your personal information and how Wazimo will treat it.Table of Content
In this policy, references to Wazimo, or to "we" or "us" are to Wazimo Media Ltd., which is a registered company in the state of Israel (No. 515286839) at Rothschild Blvd 73, Tel Aviv, Israel. Individuals wishing to contact us about data protection issues may do so by writing to us at the above address or by emailing us at [email protected]2. Your acknowledgment of this policy
We collect from Users of our Site, two types of data and information:
3.1. Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”). You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including:
(i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc; and
(ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers such as Quantcast and Google Analytics to obtain detailed analytics on the device and the User's behavior on the Site. Please note that we or our third party service providers will collect such Technical and Behavioral Information by using certain technologies such as Cookies (as further detailed below under Section 12 "Cookies and Similar Technologies").
3.2. Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:
3.2.1. Personal Information which is provided voluntary:
• Communications with Wazimo: Personal Information you provide us as part of any communications with Wazimo, by any means, including by approaching our customer services.
• Contact Details: when you provide us with your contact details via the Contact Form on the Site, we will ask you to provide us some or all of the following details: full name, e-mail address and title. A free text message may also be provided. You may also voluntarily join our mailing list by providing us with your email address.
3.2.2. Personal Information collected via technology:
• Geolocation data: while using the Site we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of IP addresses and other similar information to determine your location for the purpose of providing a localized version of our Site and for security purposes.
• Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 3.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
• Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), mobile advertising identifiers (such as Apple IDFAs and Android Advertising identifiers) or another unique identifiers.
• Data collected for sending push notifications: Subject to your consent to receive push notifications, we, via our service providers, will collect all or part of the following information: mobile advertising identifiers (such as Apple IDFAs and Android Advertising identifiers), email addresses, IP address, device push token, precise location (e.g., GPS-level) data, network information, language, time zone, product preferences, and privacy preferences. Such information will be used for cross-app, cross-device, and other interest-based advertising, analytics and market research.
3.3. Please note:
• We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
There are two main methods we use to collect information:
4.1. We collect information through your entry, connection, access and/or use of the Site. In other words, when you access or use the Site we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.
4.2. We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide via the Contact Form on our Site. We will inform you prior to collecting your Personal Information if it is requested on a voluntary basis and the consequences of not providing voluntary Personal Information.
5.1. Non-personal Information is processed in order to:
• Enhance the User’s experience on the Site;
• Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and
• Keep the Site safe and secured and for prevention of fraud.
5.2. Personal Information is processed in order to:
• Enable the operation of the Site;
• Display, deliver and develop direct marketing;
• Add your contact details to our mailing list for the purposes of providing you with special offers, promotions and information from us and from our select third parties by email and/or web-browser notification (having first obtained your consent and subject to your right to opt-out of marketing messages at any time by following the instructions in such message, by changing your browser settings for push notifications or by contacting us at: [email protected]
• Tailor advertising to your interests, including advertising displayed on our Site, advertising displayed on third party websites and mobile applications, and offers and advertising you may receive offline or as push-notifications, from us or from third parties;
• Personalize your experience on the Site (e.g. geolocation data shall be used to provide you with a localized version of the Site (where available));
• Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
• Conduct internal operations, including troubleshooting, data analysis, testing, market research, measuring and analyzing visitor traffic and for statistical purposes;
• Keep the Site safe and secured and for prevention of fraud and crime;
• Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site;
• Maintain our data processing records and general administrative purposes;
• Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.
Note to our Users in the EU:
In order for Wazimo to process your Personal Information, as detailed herein, such processing must be justified by a "basis" for processing. Please note that the Personal Information processing
activities detailed herein may be justified on the basis that:
• the processing is necessary to comply with a legal obligation - we may process your Personal Information for disclosure of information to authorities; and
• the processing is in our legitimate commercial interests - subject to your interests and fundamental rights, under our legitimate interest in offering the public comfortable, personalized and safe access to our Site, we shall process all other Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site, assisting us to prevent crime and fraud, our internal operations, maintaining records and email tracking. We may also use the information contained in certain cookies and other such files or tags consists based on such ground for our legitimate interests in a safe and user-friendly presentation of our Site. Note to non-EU Users: BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.
6.2. In addition to using the information collected by us for the purposes described under Section 4 above, we may also share your information in the following cases:
• Wazimo Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of Wazimo for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 5 above). Please note that all Wazimo personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
• Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processers who perform services on our behalf, including without limitation, companies that provide analysis, advertising retargeting and behavioral advertising services, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party's cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 10 below.
• In addition, we may share Personal Information in the following cases:
(a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
(c) to detect, prevent, or otherwise address fraud, security or technical issues;
(d) to protect the rights, property, or personal safety of Wazimo, its Users or the general public; and
(e) when Wazimo is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Wazimo (while such acquired company or investor may be located in countries outside of your jurisdiction).
6.3. For avoidance of doubt, Wazimo may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.
Wazimo acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: [email protected] and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:
• Right to access: you may have the right to request a review of your Personal Information held by Wazimo.
• Right to erasure: under certain conditions, you may be entitled to require that Wazimo will delete or "block" your Personal Information (e.g. if the continued processing of those data is not justified).
• Right to Portability: you may have the right to transfer your Personal Information between data controllers (i.e. to transfer your Personal Information to another entity).
• Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either "public interest" or "legitimate interests", those lawful bases are not absolute, and you may have a right to object to such processing. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
• The right to restrict processing – under certain circumstances, you may have the right to object to the processing of your Personal Information due to your particular situation.
• Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.
To exercise these rights, where applicable, please contact us by sending an email to: [email protected]
Note to our Users in the EU:
If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries. In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EEA, which may include the following:
• Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;
• Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;
• Transferring your Personal Information to organizing that are Privacy Shield Scheme certified, as approved by the European Commission.
BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.9. Minors
The Site is intended for Users over the age of sixteen (16). Therefore, Wazimo does not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site.10. Third Party Service Providers and Third Party Software
10.2. Note, that we collect, hold and/or manage your Personal Information through Wazimo's authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.
10.3. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.
10.4. Such third parties service providers include without limitation the following categories of service providers: ]Please complete and add additional categories of service providers if applicable (no need to list all service providers but all categories and notable examples under each category)]
web beacons, pixels, clear gifs and other similar tools (collectively, "Cookies") on our Site [to recognize your device from those of other Users of the Site, to improve the Site's performance,
to deliver a better and more personalized service according to the User's individual interests and the device or browser used, to track Users' use of the Site, to gather information about the
Users' approximate geographic location (e.g. city) to provide localized content, to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to
allow integration of the certain features of the Site with certain social networks, to develop our Site, to serve cross-app, cross-device, and other interest-based advertising.
information that identifies you, and will instead collect more general information such as how Users arrive at and use our Site, or a User’s general location.
12.3. First and third party Cookies - First-party Cookies are Cookies that belong to us and that we place on your device. Third-party Cookies are Cookies that another party, which provides us a service, places on your device through your use of our Site. For example, to administer our Site and for research purposes, we have contracted third-party service providers to track and analyze statistical usage and volume information from our Site Users. Third-party Cookies may also be placed on your device by our business partners so that they can use them to advertise products and services to you elsewhere on the Internet and/or mobile applications.
12.4. Do we track whether users open our emails? Our emails may contain a single "web beacon pixel" which enables us to verify whether our emails (and any links or advertisements within the email) are opened. We may use this information to determine whether our emails are of interest to Users, to approach Users who do not open our emails and verify whether they wish to continue receiving them and to inform our advertisers in aggregate of the audience size for their advertisements. Please note that such "web beacon pixel" will be deleted once you delete the email from your email account. If you do not wish the "web beacon pixel" to be downloaded to your device at all, please set your email account settings to receive emails from us in plain text rather than HTML.
12.5. What sort of Cookies does our website use? Generally, our Cookies perform the following functions: [Please advise whether Wazimo uses all types of cookies, and particularly targeting cookies]
• Essential Cookies – those Cookies are essential to navigate around the Site and use its features. For example, they allow us to remember your Cookie preferences and to verify if something is not working properly, so we can fix it quickly.
• Analytical and Performance Cookies – those Cookies are used to analyze how our Users use our Site and to monitor the Site's performance. For example, we might use performance Cookies to keep track of which pages are frequently visited and from what locations our Users come from. We might also use these Cookies to highlight Site services that we think will be of interest to you based on your usage of the Site. We generally use third party Cookies to perform these services, for example, Google Analytics.
• Functionality Cookies - those Cookies allow us to operate the Site in accordance with your preferences when browsing the Site. For example, such Cookies may recall your customization preferences, such as your preferred text size, fonts, languages and other parts of the Site that are alterable.
• Targeting and Tracking Cookies – those Cookies collect information about your activities on our Site and other websites, to provide you:
(i) Interest-based advertising or Online Behavioral Advertising, for which Cookies are placed on your device by our third party service providers to collect your web browsing activity and group together your interests in order to provide you with targeted advertisements which are more relevant to you when you visit our Site (please note that your web browsing activity history can be used to deduce certain demographic information which relate to you, such as your age and gender); and
12.6. Can a Site User block Cookies? Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a cookie is stored. However, if you block or erase Cookies, your experience of the Site may be limited. Please note that unless you block the acceptance of Cookies, the Site will utilize Cookies upon your use of the Site (all unless it is required by applicable law to provide a separate consent to use such Cookies, and in which case we will use such Cookies only after we receive your separate consent to such use and subject to your right to withdraw such consent at any time). For detailed instructions regarding the blocking of Cookies, please refer to your browser 'help', 'tool' or 'edit' section or see http://www.allaboutcookies.org/manage-cookies/. If you want to remove previously stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Site from placing further Cookies on your device unless and until you adjust you settings as described above. Opting out of performance Cookies - It is possible to opt-out of having your browsing activity within the Site recorded by performance Cookies. Please note that we use Google Analytics and Quantcast as our service providers in order to track Users' activities on the Site, including by use such services' persistent Cookies. If you prefer not to receive interest-based content and ads enabled by Quantcast, you can object and opt-out by clicking on the Quantcast “Opt Out” link at https://www.quantcast.com/opt-out. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout. Opting out of target advertising Cookies - Please note that if you want to opt out from receiving targeted advertising, this does not mean that you will receive less advertising when you use our Site, but rather that the advertising you see will not be as customized to your interests. You can visit the Internet Advertising Bureau’s consumer advice site at http://www.youronlinechoices.com/uk/your-ad-choices, which will provide you further information, a list of all Cookies that are currently set on your device and instruction on how to opt-out of each of them.
13.1. We take appropriate measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard
technologies and internal procedures.
13.2. Your Personal Information is hosted on [Please Complete] servers, which provide advanced strict security standards (both physical and logical).
13.3. Some of the security measures that we employ include, without limitation: highly secure services design and implementation using state of the art encryption and architectures mechanisms, restriction of access to your Personal Information to individuals who need access to it in order to process it on Wazimo’s behalf and implementation of a secured permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms. [Please confirm applicability or revise] Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.
13.4. Wazimo will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.
13.5. TO THE EXTENT THAT Wazimo IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, Wazimo SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.