PRIVACY POLICY

Last Updated: July 2017

This policy explains Smarketly Technologies LTD ("Company", "we" or "us") approach to online information collection, storage and use in connection with this Site, and Services, as well as the specific choices you can make about your own information. Please read this Policy carefully. By using the Site you will be deemed to have agreed to this Policy, so if you do not agree please do not use the Site.

What information we may collect

We do not know Your identity or make any efforts to reveal it, however, we may collect personal identifiable information (“PII”), such as Your name, address, email address, and telephone number, if You will voluntarily provide us such PII when You engage with the Services. If You choose to submit PII, You acknowledge and agree that we may use that information for general marketing purposes and to communicate with You by e-mail, postal mail, telephone and/or mobile devices about products or Software that may be of interest to You either from us, our parent or subsidiary companies.

We also collect non-personally identifiable information (“NPII”), such as the number of page views, link clicks, and login times, for such purposes and according to methods, as further described below.

How We Collect Information. We use various technologies to collect information from Your device and about Your activities when engaging with the Software and/or Services:

i. Submitted information. We will collect information You voluntarily submit such as Your name, email address, or other account or registration information.

ii. Log Files. We gather certain information automatically and store it in log files. The information includes internet protocol (IP) addresses (and information that can be extrapolated from it such as IP type and general location), browser type, internet service provider (ISP), referring/exit pages, operating system, data/time stamp, and clickstream data.

iii. Web Beacons and Tags. Web Beacons are electronic files with a unique identifier, and Tag is a small piece of computer code that is run by the web browser, and both are used to track Your navigation of a website or collection of sites, the completion of transactions, submittal of applications and browsing behavior. Web Beacons and Tags also enable collection of data, serve advertisement and provide related software, such as measurement or fraud prevention, on websites by allowing communication between a web browser and a server.

iv. Cookies. Cookies are small text files that are stored on Your internet enabled device (which include Your computer, tablet, or mobile device). Through the use of a cookie, we may automatically collect information about Your online activity when engaging with the Services, such as the pages You visit, the links You click, and the actions You take within the Software and/or Services. Cookies are also used to facilitate website navigation, make sure that You are forwarded to the appropriate website when You click on an ad, and generally improve Your web browsing experience. Most systems automatically accept cookies, but You can iv. usually modify Your browser setting to decline cookies. If You choose to decline cookies, please note that You may not be able to sign in or use some of the interactive features offered on or via the Services. Please also note that we use both session ID cookies and persistent cookies. A session ID cookie expires when You close Your browser. A persistent cookie remains on Your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in Your internet browser’s “help” file.

v. Non-Cookie Technology. Today’s online world is becoming increasingly complex, with a proliferation of new devices, software platforms, online software and other technology. As such, cookies are not always available. Therefore, companies are using alternative methods to distinguish computers and devices.

Information Collected By Third-Parties. We may allow third parties, including our authorized service providers, parent and subsidiary companies, affiliates, advertising companies, and ad networks, to display advertisements or place ad tags or beacons on or via our Software and/or Services. These companies may use various tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. This information allows them to deliver targeted advertisements and gauge their effectiveness.

Do Not Track Signals. The Service’s systems are not configured to respond to Web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer's online activities over time and across third-party Web sites or online services.

How We Use The Information We Collect.

We may use the information that we collect in order to fulfill Your requests for utilizing the Services, provide You customer support, improve our Services, contact You, conduct research and analysis, provide anonymous reporting for internal and external clients, and enforce our Terms of Service.

With Whom We Share Your Information.

We may use and share Your information: (1) to enable third party service providers to assist or facilitate in the provision of the Services to You; (2) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us; (3) to enforce our terms of use or to protect our rights; (4) to protect the safety of members of the public and other users of our Software and Services; (5) with any of our affiliated companies and third party marketing partners; (6) with third party research companies, vendors, administrative service providers, technology providers, and selected partners for data validation, aggregation, enhancement, verification and suppression purposes, and for research, marketing, advertising, and data aggregation purposes; or (7) for any other purpose for which You provide consent.

In the event that Company is acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from You as part of such merger, acquisitions, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how Your information is treated, transferred, or used.

While we strongly encourage advertising partners, service providers, and partners to adopt responsible approaches online marketing, Company is not responsible for the information practices of any third party entities referenced in this paragraph, which may use the information we share with the for the same purpose as we use the information, or for their own independent purposes, The collection, use, and disclosure of information by such referenced third parties are subject to their respective privacy policies, which may differ from the privacy terms contained herein. In addition, we may share aggregated information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis.

Security and Confidentiality.

We will store Your information as long as it is reasonably necessary to attain the mentioned purposes and in accordance with any applicable legal requirement. We implement standard security measures to protect Your information and to prevent unauthorized access or misuse of the information under our control. Although we routinely evaluate our practices to identify security threats or opportunities for the improvement of our Software and Services, no transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failures, and other factors may compromise data security, and accordingly, we cannot be responsible for the acts of those who gain unauthorized access, and we make no warranty, implied or otherwise, that we will prevent such access. You acknowledge and agree to assume these risks when engaging with the Services and communicating with us.

Transfer to other Countries

We processes information about our users on servers located in a number of countries. Accordingly, we may share your information with other companies in the Company Group for the purpose of them carrying out any of the activities specified in this Privacy Policy. We may also subcontract processing to or share your information with third parties located in countries, other than your home country. Information collected within the European Economic Area (“EEA”) and Switzerland may, for example, be transferred to, and processed by companies in the Company Group or other third parties identified above, located in a country outside of the EEA and Switzerland, where you may have fewer legal rights in relation to your information. However, the Company Group will only process your information as described in this Privacy Policy in every country. You expressly consent to your information being used as set out in this clause.

Notice to California Residents.

If You are resident of the State of California and would like to know how Your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please email us by clicking on the “Support” button at the Site.

In order to opt-out from disclosure of Your personal information to any third party for marketing purposes, please follow the instructions below. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

Changes to Privacy Policy

We may change the terms of this privacy policy from time to time. Any material change of this policy will be posted in the Website and You are advised to periodically check the Website and the Privacy Policy to keep up with such changes. You agree to be bound by any of the changes made in the terms of this policy. Continued use of the Software and/or Services will indicate Your acceptance of the amended terms. If You do not agree with any of the amended terms, You must avoid any further use of the Software and/or Services.

You may exercise Your right to access, rectify, cancel and object to the processing of Your PII by contacting us by clicking on the “Support” button at the Site. Your requests will be dealt within a prompt and proper manner as possible. You cannot review or remove any NPII.

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Smarketly Technologies LTD