- Information Company Collects and Receives;
- How Company Uses Your Information;
- Sharing Information with Third Parties;
- Third-Party Content;
- Social Networks;
- Cookies and Other Technologies;
- Your Rights;
- Information Obtained from Other Companies;
- Data Retention;
- Transfer of Data Outside Your Territory;
- Information Security;
- Do Not Track;
- Notice to Californian Residents – Your California Privacy Rights;
- How to Contact Company.
Information Company Collects and Receives.
When you Use the Software & Services, we automatically collect and store the following types of information:
- Technical Information. Certain technical information regarding your device, and your Use of the Software & Services and other third party software and applications installed on your device (the “Other Software”), including the device type and version number, the type, name and version of operating system and Other Software including, without limitation, their interactions with the Software & Services, ISP (Internet Service Provider), hardware version, location, Internet protocol (IP) address, anonymous user identifiers such as cookies and similar web technologies, device configuration, version of the Software & Services, and your configuration and settings of the device and the Software & Services, including language and time zone;
- Usage Information. Certain usage related information regarding your use and interaction with your device, including the Software & Services and Other Software, such as when and how you Use the Software & Services and Other Software, how you use your internet browser and internet search related applications, your language settings, the web pages you visit, applications you use and the content you see, access and utilize on such web pages and applications; for example, offerings and advertisements that you view, use and access, how you use them and your response to them (ie. clickstream data), how frequently you use them, your search queries and the non-precise location, time and date of your searches;
- Support Related Information. If you communicate with us via our support section or via email, we may also collect your email address, name and any information voluntarily submitted by you in connection with such support (for example, your name, company name, and particular support query or request).
How Company Uses Your Information.
Use of PII
As stated above, we collect the following information from you:
- IP Address;
- Install-ID (for installations of specific software such as Browser Extensions);
- Cookie Id;
- URL Referrer;
- Search terms; and
- Support Related Information.
We consider this information to be PII, meaning that without this information, we would not reasonably be able to identify you. Company processes this information on the basis that it is a data controller of the PII. This is how we use this information:
- To provide you with the search services and functionality, including providing you with the search results of our web search partners in response to your online search queries. We delete this data once our fraud and lifetime value assessment has been completed (as discussed in the next paragraphs). For this purpose, Company processes this information on the basis of a legitimate interest of an individual’s right to freedom of expression, including the freedom to hold opinions and to receive and impart information and ideas.
We will share search term and your IP address with Microsoft, our search partner who provides you with certain aspects of the search services and functionality, including the results of your search queries. To learn more about information collected by Microsoft, please click here. You can opt-out of Microsoft’s personalized advertising services by following the instructions found here.
- To detect and prevent fraud on its Software & Services.
Company needs the combination of IP Address, Cookie Id, Install-ID, URL and Search Term to conduct fraud detection on potentially fraudulent and illegal uses of the Software & Services. We need this information for 3 months to conduct this fraud analysis. Following this 3 month period, we will delete all data except for the Cookie-ID and Install-ID which we use for business performance which we discuss in the next paragraph. For this purpose, Company processes this information on the basis of a legitimate interest for preventing fraud.
In performing fraud detection and prevention, we use the services of third parties who will receive and access your PII.
- To assess the lifetime value of a user.
In our experience, business performance in search is measured over a 24 month period, including, the lifetime value of a users that use our Software & Services. For that purpose, Company retains the Cookie-ID and Install-ID and the number of search queries performed (but not the actual search query itself) performed by each ID for a period of 24 months from the initial collection. For this purpose, Company processes this information on the basis of a legitimate interest for its business operations and internal due diligence.
- Customer Support.
We also use Support Related Information you provide to us to provide you with support and handle your complaints and feedback. This information will not be connected with any other information collected from you on or through the Software & Services, including, any individual ID generated or collected by us, unless you ask as to. For this purpose, Company processes this information on the basis of a legitimate interest and performance of a contract with you.
We will retain this information for the time it takes to provide you with the support you requested and to handle your complaints. We may keep your information for longer periods in case of disputes and other legitimate reasons described in the next section “Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request”.
- Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request.
We use your PII and Support Related Information to take action in case of a dispute involving you in connection with the Software & Services and to enforce the terms and conditions applicable to the Software & Services. We also use your PII to comply with legal and regulatory requirements (e.g., the disclosure of information to law enforcement or tax authorities), and to protect against suspicious or other illegal activities.
For this purpose, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of Company’s users, its partners, or the general public). We will also share this information with our professional advisors in the scope of this purpose.
We will retain this Personal Information for the amount of time as required by law to fulfill the above purposes. This may include ensuring that we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your PII or dealings.
Use of Non-PII
Company uses non-PII information it collects for the following purposes:
- To operate and update the Software & Services, including in connection with Software & Services provided to our business partners, and to provide you with existing and new functionality and features of the Software & Services.
- to improve, fix and customize the Software & Services;
- to monitor, analyze and optimize your use of the Software & Services, including analyzing seasonal and annual usage trends and providing certain technical and usage information to our business partners as part of the services we provide; and
- to maintain and improve the quality and operation of the Software & Services, including, monitoring viewability of and interaction with advertisements, search results and other products and services provided by Company.
We retain this information for as long as necessary to fulfill our business and/or operational purposes or comply with a legal request. We may also choose to anonymize parts of your PII so that it can no longer be identifiable or attributable to any person if we want to keep it for longer periods of time than the retention periods set forth above.
Additional Sharing of PII with Third Parties.
We may also share your information in the following events:
- In the event Company goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred;
Transferring Personal Information From and Outside of the European Union
We will take appropriate steps to ensure that transfers of your PII are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end, if we as the data controller share your information with our corporate affiliates or third party service providers outside the EEA, we have – prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission) or EU – US Privacy Shield certification. We will provide further information on the means to ensure an adequate level of data protection on request.
Certain Software & Services may include content which may be in the form of apps, buttons, gadgets, advertisements, websites, products and services (including search services and advertisements) provided to you by third parties (collectively, “Third Party Content and Services“). The use of such Third Party Content and Services is subject to their privacy policies. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third Party Content and Services and your access to any Third Party Content and Services is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third Party Content and Services. You expressly relieve us from any and all liability arising from your use of such Third Party Content and Services. We recommended that you read the terms, conditions and privacy policies of such Third Party Content and Services before using or accessing any of them.
Cookies and Other Technologies.
As indicated above, the Software & Services collects or allows third parties to collect, through blocks of code called “pixels” or “web beacons”, certain information about you and send it to our servers and to our partners (either directly or indirectly). We or our partners, may package all or part of this information into small text files called Cookies and send the Cookie to your computer. As an example, Cookies may store search queries made through the Software & Services, the web pages you accessed, your interaction with advertisements presented to you via the Software & Services, features you used, your session duration and your configurations and preferences of the Software & Services. You can learn more about cookies on the Internet Advertising Bureau’s website: http://www.allaboutcookies.org.
Most browsers are initially set up to accept Cookies but you can reset your browser to refuse all Cookies or to indicate when a Cookie is sent. However, some functions of the Software & Services may not function properly if your cookies are disabled.
The Software & Services are not intended for minors in any jurisdiction and you hereby represent that you are not a minor according to you relevant jurisdiction. For example, users under the age of 13 in the United States and users under the age of 16 in the European Union are not permitted to use the Software & Services. We do not knowingly collect, use, share or disclose any personal information from minors. We reserve the right to request proof of age at any stage, so that we can verify that minors are not using the Software & Services.
We advise parents and guardians to regularly monitor their children’s use of email and other online communications and activities. Control tools that create a safer online environment for children are available from third party online services and software providers.
In the event that it comes to our knowledge that a minor is using the Software & Services, we will prohibit and block such a user from accessing the Software & Services and will make all efforts to promptly delete any PII with regard to such user, as applicable.
The following rights (which may be subject to certain exemptions or derogations), shall apply to EU users of the Software & Services:
- You have a right to access PII held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
- You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
- If you no longer want us to use your Personal Information, you can request that we erase your Personal Information. Please note that if you request the erasure of your Personal Information, we will not be able to provide you with the App which may impede your ability to use the Hardware. We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend use by a user to comply with our legal obligations, including for tax, legal reporting and auditing obligations. Also, for fraud or safety reasons, we may retain certain information about that user from processing another transaction through our website or future us of the App. We may also retain and use your Personal Information to the extent necessary because we maintain the Site to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.
- You have a right to restrict the processing of your Personal Information, for example in case when we no longer need your Personal Information for the initial purposes for which they were collected, but they may be required for the establishment, exercise or defense of legal claims.
- You have a right to obtain a portable copy of PII which is processed on the basis of your consent, or which is necessary for the performance of a contract between us. You have a right to have such portable copy of PII transferred to another data controller in a structured, commonly used and machine-readable format.
- You also have a right to request details of the basis on which your PII is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
- You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your PII. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the PII requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us – please see the “Contact Us” section for how to contact us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
In the event that your request, for example, would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with your request in a different way than initially requested, we wil address your request to the maximum extent possible, all in accordance with applicable law.
How we Protect your Information.
Do Not Track.
Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature“); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Company does not currently respond or recognize DNT Feature signals.
If you have any complaints on our processing of your PII or if you believe that we have breached our own privacy policies or applicable law, we encourage you to contact us. However, please note that applicable EU data protection laws provide you with a right to lodge a complaint with the competent supervisory authority as well.
Notice to Californian Residents – Your California Privacy Rights.
California residents who provide us with certain types of personal information (as defined under California Civil Code Section 1798.83 (also known as California’s “Shine the Light” law)) are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for their own direct marketing use. To make such a request, please contact us through the email or physical address under the “How to Contact Company” section below.
When making such a request, please ensure that you write in the subject line and the body of your message “Request for California Privacy Information”.
Please be aware that not all information sharing is covered by California’s “Shine the Light” law.
How to Contact Company.
Attention: General Counsel
26 HaRokmim Street, Azrieli Center 1
Building A, 4th Floor
Last updated: May 24, 2018