Last updated: 6 September 2018
Aktibo (collectively, “we”, “us”, or “our”) provides data analytics and tools. In the course of providing our services, including through the use of our app (“Services”), we collect certain information about our customers, website visitors and our customers’ potential customers and/or existing customers (“End Users”). This privacy notice (“Notice”) describes how we collect, use, and share the information obtained and what are the choices in connection with this use.
INFORMATION WE COLLECT
When individuals use our Services, we collect personal information, which is information that identifies someone or relates to someone an identifiable individual (“Personal Information”). We collect the following types of Personal Information:
We collect information both about our visitors of our website, customers and End Users through information the individuals provide to us actively, through cookies and other technologies and through information we receive from third parties:
Information collected from the individuals:
We collect information from you when you:
Complete our proprietary online form (“Smart Form”): If you choose to answer the questions in our smart form. The questions are about your demographics (age, gender, lifestyle or health conditions). Answering the questions is voluntary but all of the questions must be answered in order to submit the form or download the app.
Download our app: If you choose to download our app, and elect to give us permissions for this, we will collect your exact location via your mobile device’s GPS, and/or track your movements. You may also choose to upload a picture to identify yourself. Also, see your choices, your EU rights for your choices with respect to our processing of your information.
Interact with our website or Services: When you engage with our website (through our “contact us” form), or send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way, you may provide us with personal information. Please note that information you provide to us, without the parts that identify you, will be treated as non-confidential and non-proprietary and we may use it and share it with third parties.
Apply for a job: Our website includes a feature (“Careers”) that allows you to submit an online job application, if you reside in Israel or in the US. When you submit an online application, you will be required to provide personal information, including but not limited to your name, contact information, job interests, educational and job history, and references. This information will be used by us to assess and process your application.
You will also be asked to provide equal opportunities information. This is not mandatory – if you don’t provide it, it won’t affect your application. We won’t make the information available to any staff outside our recruitment team, including hiring managers, in a way that can identify you. Any information you provide will be used to produce and monitor equal opportunities statistics.
If we decide to interview you, we may print your application and use it during the interview process. If you are hired, your application becomes part of your employee file. If you are not immediately hired, your printed application is kept for six (months) and then typically will be destroyed. We may ask you to provide additional information during the interview or hiring process. We may also use the information you provide to contact you about your application; for example, to ask you to agree to a background check or to send you an offer letter.
We do not share the information you provide in the online application to anyone outside of Aktibo unless we believe it is required by law.
Information collected automatically:
are cookies that we place on your device ourselves, and third party cookies, which are cookies that we allow third parties to place on your device.
When you use our website, fill in our SmartForm or interact with any of our customers’ websites, we may place a number of cookies files in your web browser.
We use both session and persistent cookies on the Service and we use the following types of cookies. To learn how you can control information collected about you using cookies and other technologies see here.
- Essential cookies. We use essential cookies to authenticate End Users and prevent fraudulent use of user accounts.
- Preferences cookies. We use preferences cookies to remember information that changes the
way the Service behaves or looks, such as the “remember me” functionality of a registered user
or a user’s language preference.
- Analytics cookies. We use analytics cookies to track information how the Service is used so that we can make improvements. We also use analytics cookies to test pages, features or new functionality of the Service to see how our users react to them.
About users of our website:
About the End Users:
We use these technologies to track the End User’s activities in our application or across our customers websites, our website, and our SmartForm in order to provide our Services to our customers.
- For the SDK found in our app: when an End User removes the application from his or her mobile device data collection and/or tracking will be stopped.
- For removing cookies – please see your choices.
We automatically collect the following types of information when End Users access any website where our tracking cookies have been embedded (our customers’ website and our own websites) or when an End User downloads the app:
- Usage Information: urls accessed, the frequency of access, how much time you spend on each page, what you click on while on our website, when you accessed the website, traffic channel, referral, and timestamp
- Location Information: information about your estimated location, which may be determined from the IP address. If you provide us with permission for this we will collect your precise location (derived from your mobile device’s GPS) as well as your movements. You may revoke this permission at any time.
- Device Information: information about the device you are using, such as hardware model, operating system, application version number, browser, and IP
Information Collected From Third Parties
In order to provide you with the Services, we collect and store information from the following third parties about your End Users:
- We receive from third party data brokers: information about individuals that includes their cookie stream information and information collected through tags. We also receive information from public databases like the census bureau.
- We receive information from social media networks if you choose to engage with our social media widget or sign up to our SmartForm or app using your social media account.
We combine information collected through the app or cookies on our customers’ sites with information we receive from data brokers and public databases to analyze it to better understand the End Users’ behaviors and attributes.
HOW WE USE PERSONAL INFORMATION
We use personal information to provide our Services to our customers, to communicate with our customers, website visitors or End Users, to provide technical support, and, with respect to information collected from customers or website visitors (but not from End Users) to improve our Services and customer relations.
To the extent EU data protection law applies to our processing of personal data about our customers or our website visitors [or any personal data that we incorporate in our database for use with various customers] we act as the “data controller”. To the extent EU data protection law applies to our processing of personal data about End Users in the course of providing the Services to our customers we serve as the “data processor” and process information in accordance with the instructions of our customers, the data controllers.
We process personal information of our customers and of the End Users for the following purposes as necessary to provide the Services to our customers and perform our contract with our customers:
- Provide Services: We use our customers’ personal information and that of End Users to provide the Services to our customers which includes analyzing and determining trends in and attributes of the End Users’ behavior and providing reports of such to our customers. In some cases, our processing of End User information, and the customer’s use of such information may require the End User’s consent. It is the customer’s responsibility to disclose clearly, and obtain consent as required by applicable data protection law.
- Communicate And Provide Technical Support: We use personal information to communicate with our customers or End Users about the Services, to send account updates or other communications regarding the Aktibo account (through emails or through push notifications via the app) or to inform of any changes to our website or Services, and to provide support or other Services you request.
We process personal information of our customers or website visitors, but not that of End Users, for the following purposes as part of our legitimate interest in the improvement and marketing of our Services, and in the security of our Services. We apply appropriate safeguards to protect this information including as described here, here and here.
- Communicate About New Features: We send you notifications about new features or information available on our Services or that we feel might be of interest to you. Email email@example.com to learn how you can opt out of receiving these communications at any time.
- Maintenance and Improvement: We use personal information to identify your interests and needs in order to provide you with more tailored, relevant, and intelligent services. We also use information that we collect to diagnose any problems with our website and to improve the user experience.
Benchmarking: We aggregate information, collected from our End Users to gain insights into our Services. For example, to calculate the percentage of End Users in a particular city or country, or industry.
In our processing of your information, we also share your personal information to defend our rights and the rights of others, to efficiently maintain our business, and to comply with the law as described in how we share your information.
We share information of our visitors, customers and End Users with certain third parties, including our service providers that facilitate our Services, and as necessary to comply with our legal obligations. The legal basis for this is our legitimate interest in providing the Services, complying with the law and protecting our rights and those of others. We apply appropriate safeguards for this sharing of your information as described below and in the security section, choices section, and EU rights section.
- Service Providers: We share information with service providers that help us perform website functions and administer our Services.
- Corporate Structure: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
- To Prevent Harm: We will share information if we believe it is necessary to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
- Legal Purposes: We will share information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights or contractual obligations; to defend against legal claims or demands; or to comply with the requirements of any applicable law.
- With Your Consent: Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time.
We implement and maintain reasonable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. We have implemented various policies including, encryption, access, and authentication to guard against unauthorized access to personal data in our systems.
Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.
TRANSFERS OF INFORMATION
If you are located outside United States and choose to provide information to us, please note that
we transfer the information, including personal information, to United States and process it there.
The laws in the United States may not be as protective of your privacy as those in your location. For example, United States law does not provide you with the right to access, modify and delete personal information in all cases. Further, government entities in the United States may have certain rights to access your personal information. When transferring personal information to and processing personal information in the United States we will implement appropriate safeguards and process the personal information in accordance with the terms of this Privacy Notice.
YOUR CHOICES WITH RESPECT TO YOUR INFORMATION
Access, correct or delete your information: End Users who have downloaded the app may access their account to access, correct or delete the information provided to us and which is associated with the account by logging into the account on the app or by emailing us at firstname.lastname@example.org.
In the event that we refuse a request under rights of access, we will provide the individual with a reason as to why. Individuals residing in the EU also have the rights described in Your Rights Under EU Data Protection Law section, and to complain as described in Complaints & Inquiries section below.
We will retain your information after your account is deleted under the circumstances described
in the “How Long We Keep Your Information?” section.
Delete your account: You may request that we delete your account by contacting us at email@example.com. If you choose to delete your account, we will begin the process of deleting your account from our systems. We will retain your information after your account is deleted under the circumstances described in the “How Long We Keep Your Information?” section.
Emails: You can opt out of receiving promotional e-mails from us by clicking the “unsubscribe” link provided in each e-mail or by contacting us at firstname.lastname@example.org. We will continue to send you notifications necessary for the Services related to this e-mail address.
All cookies: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
- For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
- For the Internet Explorer web browser, please visit this page from Microsoft: https://support.microsoft.com/kb/278835
- For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
- For any other web browser, please visit your web browser’s official web pages.
Google Analytics: See https://policies.google.com/technologies/partner-sites for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here https://tools.google.com/dlpage/gaoptout.
FOR EU INDIVIDUALS: YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION
If EU data protection law applies to our use of your information, you have rights that are explained
below. The rights available to you depend on the reason for our use of your information.
If you are an End User of our customer: If you have downloaded the app – you can review your information, amend or delete it through the app. If you would like to access, amend or delete any information not found in the app account, or with respect to other End Users that have not downloaded an app – you need to contact our customer (the “data controller”) directly and we will respond within a reasonable period of time to any such request by our customer.
If you are our customers: You may access your Aktibo account to access, correct, amend, or delete the information as explained here.
Your request should contain a detailed, accurate description of the data you want access to. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.
- The right to access: You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the information we process.
- The right to rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- The right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
- The right to restrict processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
- The right to object to processing: You have the right to object to processing if we are able to process your information because the process is in our legitimate interests.
- The right to data portability: This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another, or give it to you.
- The right to lodge a complaint with the supervisory authority. A list of Supervisory Authorities is available here: https://ec.europa.eu/info/law/lawtopic/data-protection_en.
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
HOW LONG WE KEEP YOUR INFORMATION
You can delete your account or request that we delete your account by writing us at email@example.com.
We will retain your information until the earlier of (i) the information is no longer necessary to accomplish the purpose for which it was provided; or (ii) you delete your account as stated above. We will retain your End User’s information until the end of the Services engagement with you or pursuant to a legally binding request for erasure or as otherwise set forth in a binding agreement between us. We retain your information or that of your End User for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements.
To read more about specific reasons we would retain some data for longer periods of time click here:
- Security, fraud & abuse prevention – i.e. to protect you, other people, and us from fraud,
abuse, and unauthorized access.
- Financial record-keeping – when you make a payment to us we are often required to retain this information for a longer period of time for purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations.
- Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.
- Direct communications with us – if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.
Even if you delete your account, keep in mind that the deletion by our third party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. For any privacy or data-protection-related questions, please write to firstname.lastname@example.org.
DO NOT TRACK DISCLOSURE
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. For further details, visit https://www.eff.org/issues/do-not-track.
LINKS TO OTHER SITES
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or Services.
This website and our Services are not intended for individuals under the age of eighteen (18) years. Accordingly, we do not knowingly collect or share information from children without parental or guardian consent. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us using the information below, and we will delete that information from our databases.
CHANGES TO THIS PRIVACY NOTICE
We may change this Privacy Notice from time to time. We will post the changes to this page, and will indicate the date they go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights we will notify you of the changes by posting a prominent notice on our website or using other methods that we select, such as sending you an email.
If you have any questions about this Privacy Notice, please contact us via Email: email@example.com
Address: 30 HaNatsiv St., Tel Aviv, Israel 6701506, Phone: + 972-3-6822033