SPOTEER LTD. PRIVACY POLICY

[Last Updated: May 8, 2018]

 

This privacy policy (“Privacy Policy“) provides important and transparent disclosures of the data collection and use practices by Spoteer Ltd. (“Company”, “us”, “we” and “our”). This Privacy Policy applies to the data collected from individuals who (a) use our owned and operated websites including but not limited to www.spoteer.com and app.spoteer.com (“Company’s Websites” and “Company’s Websites’ User(s)” in correspondence); (b) use any other subdomains and third parties’ sites and applications, implementing our SDK (“SDK”) and or pixels, (“Third Party App(s)” and “Third Party App(s) User(s)” in correspondence). Company’s Websites’ User(s) together with Third Party App(s)’ User(s) together, shall be referred to as “User(s)”.

 

Our technology and services enable our business partners to show Users relevant advertising, based on users’ interests and behaviors. In order to provide these services, we collect and use certain information about Users’ activity and preferences, all as detailed in this Privacy Policy.

 

This Privacy Policy is an integral part of the Company’s Terms of Service (available at [add link]) (collectively: the “Terms”), and is a legally binding agreement between the User and the Company. By using a Third party App or Company’s Websites or services, as applicable, you hereby agree to the Terms and to the collection and use of certain data, all as described in this Privacy Policy. Any use or continued use of the Third Party App or Company’s Websites or our services constitutes your agreement and consent to this Privacy Policy. Company’s Websites’ User, who does not agree to the Terms, shall not access or use Company’s Websites.  Third Party App(s) User, who does not agree to the Terms, may disable the Third Party App’s Geo tracking through his device’s settings and contact us at legal@spoteer.com and we will cease our data collection from such device.

 

The Company may collect certain information about your device applications, web usage and sites you have visited, which may be shared with third parties and used for advertising. In order to protect your privacy and make sure you understand exactly what information may be collected about you, we have set up this Privacy Policy.

 

We may collect two types of information from the Users. The first type of information is non-identifiable information which may be made available via the use of the Company’s Website or from the use of Third Party Apps. Thus, we are not aware of the identity of the User from which the Non-Personal Information was collected (“Non-Personal Information”).

 

The Non-Personal Information collected by us may include technical information about your device (type of browser, such as type of device, operating system, settings and system configurations, installed languages, other installed applications, IP address, Android ID or Advertising ID, IDFA or device ID and other unique device identifiers, and mobile network information), as well as your activity using the Company Website and platform and/or services (such as data about the webpages you access, traffic to and from websites, the dates and times associated with transactions, log data, your ISP, the time and date you access the Company’s Websites or Third Party Apps, pages viewed, Items views or Items saved, date and time stamp, duration on the page, location data (if you have that functionality set up),  etc.

Please note that we consider this data to be Non-Personal Information, however, in some countries and jurisdictions this data might be considered as identifying and “Personal Information”.

We use this information, which does not identify individual Users, to analyze trends, to administer Company’s Websites, to track Users’ movements around the Company’s Websites in order to ensure that our Website’s content is presented as effectively as possible as well as to gather demographic information about our User base as a whole. We also use this information in order to (a) gather statistical data regarding exposure to static and digital out of home campaigns, as well as (b) to better target Users with relevant digital out of home advertisements.

 

The second type of information is Personal Identifiable Information.

Personal information” is information that identifies or may identify you, or may be of a private or sensitive nature.  This information may include your name, email address and telephone number. We may collect such information in a variety of ways, including, but not limited to, when Users use or visit the Company’s Websites, subscribe to the newsletter, respond to a survey, fill out a form, contact us and in connection with other activities, services, features or resources we make available thereof.

 

How We Collect Information

 

  • Data collection from Third Party Apps. We collect Users’ information through our SDK which is integrated in Third Party Apps, in order to allow the tracking and collection of the Users’ information set in this Privacy Policy. By downloading and/or using a Third Party App, you grant the Third Party App developer with permission to collect such information and share it with us pursuant to the acceptance of the Third Party App’s privacy policy. We may track this information over time and across multiple apps (and may also combine the device information with Non-Personal Information from other sources) in order to deliver targeted digital out of home advertisements.
  • Data Collection through Other Technologies
  • Cookies. Cookies are small data files that have unique identifiers and reside, among other places, on your devices, in emails we may send to you, and on the web pages of the Company’s Websites. We may permit certain third parties to place cookies through the Company’s Websites as those help us improve and personalize your use of the Company’s Websites and to provide relevant advertising to you. These third parties may collect information about your online activities over time and across different websites when you use the Company’s Websites.  Most browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your experience through the Company’s Websites may be limited.
  • Web Beacons. Web beacons are electronic images that may be used on the Company’s Websites or in emails we may send you from time to time. We use web beacons to deliver cookies, count visits, understand usage and effectiveness of offers, and tell whether you open an email and act upon it.
  • Do Not Track. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not currently respond to DNT signals.

How Collected Information Is Used

The Users’ information collected as set forth herein, allows us as well as our business partners, to gain a better understanding of Users’ interests as well as behavioral patterns, in order to provide the Users with targeted personalized content, including digital out of home advertisements which we believe may interest the Users. We may use your information in order to:

  • Operate, manage and improve the services provided by the Company;
  • To send periodic emails;
  • To personalize User(s)'(s) experience
  • To respond to User’s requests and support the Company’s costumers’ needs more efficiently;
  • Protect the rights or property of the Company or third parties; and
  • To provide User(s) with content the Company or its business partners believe may interest such User(s), such as targeted advertising content or other commercial information or enable our business partners to do so.

How we protect Your Information

Your privacy is very important to us and we are committed to protecting your Personal Information from unauthorized access, use or disclosure. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our services, and we make no warranty, express, implied or otherwise, that we will be able to prevent such access. The Company may adopt what it believes is appropriate data collection, storage and processing practices and security measures to protect against unauthorized access to such data.

 

How Collected Information Is Shared

  • The Company may use third party service or software providers in order to help it operate its business and/or technologies, or to administer activities on its behalf. For this purpose the Company may share information it accepts or collects from Users. For example, the Company may share User’s information in order to provide Users with certain content or advertisements which the Company or other third parties may think will be of interest to the User (such content may be provided either by the Company or by other third parties at its choice).
  • Third Party Analytics Technologies. The Company may use third parties’ analytic and other tools to better understand users’ movements’ patterns, the usage of Company Websites by users and how to improve the Software. These third parties may use cookies, pixel tags or other technologies to collect and store anonymous information such as the time User visits certain places, Webpages, the places or Webpages visited by the User, time User spends on each place or Webpage, Device Identifiers, type of operating system and browser used, and Affiliate Referral URLs. These third parties will provide the Company with this information in part to help it understand and analyze shopping habits and other trends to enable it to improve its targeting, software and services.

Credit card information is neither saved by Spoteer nor shared with third parties. This Privacy Policy does not apply to any of any third parties specified in this Privacy Policy. The Company does not have access to, nor control over, third parties’ use of cookies or other tracking technologies. User is advised to consult the respective privacy policies of these third parties to see his options for opting out of their use of such devices.

 

Information Warranty Disclaimer

Notwithstanding anything else in this Privacy Policy, the Company is not responsible for the accuracy, correctness and security of any of the information Company gather’s, store’s and disclose to User or to anyone else.

 

Children’s Privacy

You represent and warrant that you are at least 13 years of age and of legal competence to enter into this Privacy Policy. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians.  If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at legal@spoteer.com. If the Company becomes aware that a child under 13 has provided it with Personal Information, it will delete such information from our files.

 

Transfer of Data

We may store or process Users’ personal information in Europe. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer and storage of your data in Europe.

 

Contacting Us

For any lack of clarity with respect to this Privacy Policy or the privacy practices employed in the Software, Users may contact the Company at legal@spoteer.com

 

Data Access and Retention

The Company values User’s privacy and control over User’s Personal Information, and therefore, In case personal identification information is collected, User is at any time and Subject to applicable law, entitled to authorized in writing or through his/her legal guardian, to notify the Company that he wishes to either review the personal information or delete it, User can notify the Company by sending us an email to legal@spoteer.com. In order to delete or allow User to review the personal information, the Company may require that User will provide it with identifying information in order to allow such review.  Please note that unless you instruct us otherwise, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements. .

 

Changes to this Privacy Policy 

This Policy may be revised from time to time at Company’s sole discretion. The last revision will be reflected in the “Last modified by” heading and will become effective immediately. We encourage you to review the Policy periodically to ensure that you understand how we collect, use and share information through our services.