[Last Modified: July 18, 2023]
CodeFuel is a technology and media company that provides a range of services. We display advertisements, sponsored content or search results provided to us by our search feed partners or advertisers (“Services”). The Services may be offered to by other companies including through apps, sites or products that display to you search results and ads by linking to our Services, or by our own developed extensions, software or apps that display the ads and search results through the Services (“CodeFuel Apps” or “Apps”).
1. POLICY AMENDMENTS
2. CONTACT INFORMATION AND DATA CONTROLLER INFORMATION
- Data Protection Officer: email@example.com.
26 HaRokmim Street, Azrieli Center, Building A, 4th Floor
Holon 5885849, Israel
- Data Protection Representative for Data Subjects in the EU and UK:
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, please visit the following website. https://prighter.com/q/11106546394.
Attn: Andreas Mätzler
3. DATA SETS WE COLLECT AND FOR WHAT PURPOSE
We may collect two types of information from you, depending on your interaction with us.
The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your action in the website or Services (such as session duration).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data” or “Personal Information” as applicable under law).
For the avoidance of doubt, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:
We use various technologies to collect and store the data sets listed above, including cookies, pixel tags, local storage, databases and server logs. We use different technologies to process your information listed above, for the purposes listed above. We use systems that analyze your activity to provide you with customized search results, personalized ads, or other features tailored to how you use our services. We analyze your activity also to detect abuse such as spam, malware, and illegal content.
Therefore, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of Personal Data to third party countries as further detailed in Section 10 “INTENATIONAL DATA TRANSFER” below, 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 our policies and agreements, 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.
4. HOW WE COLLECT YOUR INFORMATION
5. COOKIES AND SIMILAR TRACKING TECHNOLOGIES
When you browse our website, we, or our third party vendors, place “cookies”, “pixels” or “web beacons”, that collect certain information about your usage and interaction with the website and use this information for marketing CodeFuel and the Services CodeFuel offers, to find leads and prospects, as detailed in the table above. We also use these tools for analytic purposes as detailed above.
You can find more information about cookies at www.allaboutcookies.org.
Please see our cookie list, as well instruction on how to change your cookies settings and preferences at any time, available through our website footer.
6. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your Personal Data with third parties, including with Business Partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.
Where we share information with services provider and agents, we ensure they only have access to such information that is strictly necessary in order 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).
Further, for the avoidance of doubt, we may transfer and disclose or otherwise use Non-Personal Data or information which is linked to anonymous random identifiers or information that is aggregated in a non-identifiable way, at its own discretion.
7. USER RIGHTS
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, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
For detailed information on your rights and how to exercise your rights, please see the Data Subject Request Form (“DSR”) available here.
Certain rights can be easily executed independently by you without the need to fill out the DSR Form:
- You can correct or delete the Contact Information or Account Data at any time, through the account settings on the website;
- You can you can opt-out from receiving our marketing emails by clicking “unsubscribe” link;
- you can withdraw consent for processing Personal Data for analytics or marketing purposes, by using the cookie settings on the website, or as detailed in the section below:
8. DATA RETENTION
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 will express your preference to opt-out, where applicable.
The retention periods are determined according to the following criteria:
- For as long as it remains necessary in order to achieve the purpose for which the Personal Data was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.
- To comply with our regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
- To resolve a claim we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.
Other circumstances in which we will retain your Personal Data 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 if our intention to do so.
9. SECURITY MEASURES
We work hard to protect Personal Data we process from unauthorized access or unauthorized 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 amount of data that we store on our servers, restrict access to Personal Data to CodeFuel employees, contractors and agents, etc. Note that, we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.
10. 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 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 (SCCs).
Additionally, following the withdrawal of the United Kingdom (UK) from the European Union on January 31, 2020, the UK is no longer considered to be a part of the EEA and therefore, the transferring of Personal Data from the EEA to the UK will also be subject to the SCCs or other contractual clauses that will ensure the security of the Personal Data (pending an adequacy decision from the European Commission). Further, the transfer of Personal Data collected within the UK to countries outside the UK, will be provided with sufficient safeguards as required under applicable laws, including pursuant with the UK standard contractual clauses (UK SCCs) as approved by the UK Information Commissioner Office (ICO).
11.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 with respect to 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 that we receive from a user that is considered a “child” immediately upon our discovery 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.
A. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS
This section applies to California residents only pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.
Please see the CCPA Privacy Notice here which discloses the categories of Personal Information collected, purpose of processing, source, categories of recipients with whom the Personal Information is shared with for a business purpose, whether the Personal Information is sold or shared, the retention period, and how to exercise your rights as a California resident.
B. ADDITIONAL NOTICE TO COLORADO RESIDENTS
Under the Colorado Privacy Act (“CPA”) if you are a resident of Colorado, acting as an individual or in the household context only (and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context), your rights with respect to your Personal Data are described below.
“Personal Data” as defined in the CPA means: “information that is linked or reasonably linkable to an identified or identifiable individual” and does not include publicly available information, de-identified or aggregated consumer, and information excluded from the CPA scope, such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of Substance Use Disorder Patient Records”, Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the Driver’s Privacy Protection Act of 1994, Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights and Privacy Act of 1974, national Security Exchange Act of 1934, higher education data and employment data.
“Sensitive Data” as defined in the CPA include (i) racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation; (ii) Genetic or biometric data that can be processed to uniquely identify an individual; or (iii) child data. We do not process or collect any sensitive data.
YOUR RIGHTS UNDER CPA
The table below details how Colorado consumers can exercise their rights, and appeal our decisions regarding their exercise requests.
2.Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
4.Comply with the law or legal obligation.
5.Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
6. nable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
7. Make other internal and lawful uses of that Personal Data that are compatible with the context in which you provided it.
We will delete or de-identify Personal Data not subject to one of these exceptions from our records and will direct our processors to take similar action.
HOW TO SUBMIT A REQUEST UNDER CPA?
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Data. If the DSR is submitted by someone other than the consumer about whom information is being requested, proof of authorization (such as power of attorney or probate documents) will be required.
We will respond to your request within 45 days after receipt of a verifiable Consumer Request and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at email@example.com and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/.
If you have an account with us, we may deliver our written response to that account or via email at our sole discretion. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You do not need to create an account for submitting a request.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
C. ADDITIONAL NOTICE TO VIRGINIA RESIDENTS
Under the amended Virginia Consumer Data Protection Act (“VCDPA”), if you are a resident of Virginia acting solely in an individual or household context (and not in an employment or commercial context), you have the following rights with respect to your Personal Data.
“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information. Personal Data does not include de-identified data or publicly available data, and information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.
HOW TO SUBMIT A REQUEST UNDER VCDPA?
We shall respond to your request within 45 days of receipt. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days. If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at firstname.lastname@example.org and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows: Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.
We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you or your request, we will not be able to grant your request.
D. ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS
Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the “CDPA”) if you are a resident of Connecticut, acting in an individual or household context (and not in a commercial or employment context or as a representative of business, non-profit or governmental entity), your rights with respect to your Personal Data are described below.
“Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable individual. It does not include de-identified data or publicly available information. If further does not include information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher education, employment data and FCRA, Driver’s Privacy Protection Act of 1994, Family Educational Rights and Privacy Act, Farm Credit Act.
The categories of Personal Data processed, purpose of processing, are detailed in Section 3, categories of personal data shared with third parties, categories of third parties with whom data is shared, are detailed in Section 6. Disclosure of sale of data or targeted advertising is detailed in in the DSR Form available here. Further, the table appears under Section B. above details the rights you have under CDPA and how you may exercise your rights.
HOW TO SUBMIT A REQUEST UNDER CDPA?
We shall respond to your request within 45 days of receipt. The response period may be extended once by 45 additional days when reasonably necessary, taking into account the complexity and number of requests, provided we inform you of such extension within the initial 45 days response period, together with the reason for the extension.
If we decline to take action on your request, we shall so inform you without undue delay, however no longer than within 45 days of receipt of your request. The notification will include a justification for declining to take action and instructions on how you may appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Connecticut Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.
We shall provide information in response to your request free of charge, up to twice annually, unless requests are manifestly unfounded, excessive or repetitive. If we are unable to authenticate your request using commercially reasonable efforts, we may request additional information reasonably necessary to authenticate you and your request. If we cannot authenticate you and your request, we will not be able to grant your request.