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Privacy Policy

Preamble We are very delighted that you have shown interest in our enterprise, a digital system containing a Website and Apps (hereinafter, jointly and severally, the "System"). Data protection is of a particularly high priority for the management of the Medidate system. The use of the Internet pages of Medidate system, accessible from www.medidatewith.me, and/or the Apps on Google Play or Apple's Play Store, is subject to cookies as detailed herein which is possible without any indication of other personal data; however, if a data subject wants to use special enterprise services via our System, processing of personal data could become necessary. The processing of personal data, such as the name, address, e-mail address, telephone number, transaction & payments data of a data subject is in line with the General Data Protection Regulation (GDPR) and CCPA. By means of this data protection declaration, our enterprise would like to inform of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled. As the controller, Appum Studios Ltd ("Appum") has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this System. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us. Consent By using our System, you hereby consent to our Privacy Policy and agree to its terms. We do not knowingly collect any personal Identifiable data from children under the age of 13. If you think that your child provided this kind of data on our System, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such data from our records. If you are under the age of 13 you are not allowed to register our services and we encourage you to ask the registration of your parents instead. 1. Definitions Our data protection declaration should be legible and understandable for the public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, inter alia, the following terms: a) Personal data Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. b) Data subject Data subject is any identified or identifiable natural user, whose personal data is processed by the controller responsible for the processing. c) Processing Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. d) Restriction of processing Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future. e) Profiling Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyses or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements. f) Pseudonymization Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person. g) Controller or controller responsible for the processing Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. h) Processor Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. i) Recipient Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing. j) Third party Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data. k) Consent Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. 2. Name and Address of the controller Controller for the purposes of this Privacy Policy: APPUM STUDIOS LTD. A private company, incorporated and registered under the Israeli laws Address 6 Haharuv road, Shilat, Israel. appumstudio@gmail.com 3. Name and Address of the Data Protection Officer The Data Protection Officer of the controller is: Matan Dahan Address 6 Haharuv road, Shilat, Israel. appumstudio@gmail.com Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection. 4. Cookies Like any other System, www.medidatewith.me uses 'cookies'. These cookies are used to store information including visitors' preferences, and the pages on the System that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information. Using cookies, Appum can provide the users of this System with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our System can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our System users. The purpose of this recognition is to make it easier for users to utilize our System. The System user that uses cookies, e.g. does not have to enter access data each time the System is accessed, because this is taken over by the System, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie. The data subject may, at any time, prevent the setting of cookies through our System by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our System may be entirely usable. 5. Collection of general & personal data and information The System collects a series of general data and information when a data subject or automated system calls up the System. This general data and information are stored in the server log files. We follow a standard procedure of using log files. These files log visitors when they visit Systems. The information collected by log files may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the System from which an accessing system reaches our System (so-called referrers), (4) the sub-Systems, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the System, and gathering demographic information. When using these general data and information, Appum does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our System correctly, (2) optimize the content of our System as well as its advertisement, (3) ensure the long-term viability of our information technology systems and System technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Appum analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject. Personal data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal data. If you contact us directly, we may receive additional data about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other data you may choose to provide. When you register for an Account, we may ask for your contact data, including items such as name, company name, address, email address, and telephone number. When you process a payment transaction you may also ask to provide your name, email, billing or shipping address and in some cases your transaction history to authenticate you. We use the personal data we collect in various ways: • Provide, operate, and maintain our System & services • Improve, personalize, and expand our System & services • Understand and analyze how you use our System & services • Develop new products, services, features, and functionality • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the System, and for marketing and promotional purposes • Process your transactions & payments • Send you emails • Find and prevent fraud More details are elaborated below. 6. Registration on our System The data subject has the possibility to register on the System of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes including providing services to you and process transactions. The controller may request transfer personal data to one or more processors (e.g. a parcel service, or payments processors) that also uses personal data for an internal purpose which is attributable to the controller. By registering on the System of the controller, the IP address assigned by the Internet service provider (ISP) and used by the data subject, date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents and services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller. The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller's employees are available to the data subject in this respect as contact persons. 7. Subscription to newsletters On the System of Appum, users may be given the opportunity to subscribe to our enterprise's newsletter. The user input used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller. Appum informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping. During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller. The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the System of the controller, or to communicate this to the controller in a different way. 8. Newsletter-Tracking The newsletter of Appum contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Appum may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects. Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. After a revocation, these personal data will be deleted by the controller. Appum automatically regards a withdrawal from the receipt of the newsletter as a revocation. 9. Contact possibility via the System The System of the Appum contains information that enables a quick direct electronic communication with us, which also includes an e-mail address. If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. 10. Routine erasure and blocking of personal data The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to. If the storage purpose is not applicable, or if a storage period prescribed by GDPR or CCPA or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements. 11. Rights of the data subject Under GDPR a) Right of confirmation Each data subject shall have the right to obtain from the controller the confirmation as to whether personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller. b) Right of access Each data subject shall have the right to obtain from the controller free information about his or her personal data stored at any time and a copy of this information, as well as access to the following information by a data subject access request: o the purposes of the processing; o the categories of personal data concerned; o the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; o where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; o the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing; o the existence of the right to lodge a complaint with a supervisory authority; o where the personal data are not collected from the data subject, any available information as to their source; o the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject. Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller. c) Right to rectification Each data subject shall have the right to obtain from the controller the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller. d) Right to erasure (Right to be forgotten) Each data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary: o The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed. o The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing. o The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR. o The personal data have been unlawfully processed. o The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject. o The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Appum, he or she may, at any time, contact any employee of the controller. An employee of Appum shall promptly ensure that the erasure request is complied with immediately. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of Appum will arrange the necessary measures in individual cases. e) Right of restriction of processing Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies: o The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data. o The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead. o The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims. o The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Appum, he or she may at any time contact any employee of the controller. The employee of Appum will arrange the restriction of the processing. f) Right to data portability Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. To assert the right to data portability, the data subject may at any time contact any employee of Appum. g) Right to object Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR, namely (point e): processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or (point f): processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. Point f shall not apply to processing carried out by public authorities in the performance of their tasks. This also applies to profiling based on these provisions. Appum shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If Appum processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Appum to the processing for direct marketing purposes, Appum will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Appum for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact any employee of Appum. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications. h) Automated individual decision-making, including profiling Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, Appum shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of Appum. i) Right to withdraw data protection consent Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of Appum. Under CCPA Privacy Rights (California Consumer Privacy Act) Under the CCPA, among other rights, California consumers have the right to: Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers. Request that a business delete any personal data about the consumer that a business has collected. Request that a business that sells a consumer's personal data, not sell the consumer's personal data. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us. 12. Data protection provisions about the application and use of Google Analytics (with anonymization function) On this System, the controller has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and statistical analysis of data about the behavior of visitors to Systems. A web analysis service collects, inter alia, data about the System from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a System and to carry out a cost-benefit analysis of Internet advertising. The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. For the web analytics through Google Analytics the IP address of the Internet connection of the data subject is abridged to us when accessing our Systems from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area. The purpose of the Google Analytics component is to analyze the traffic on our System. Google uses the collected data and information, inter alia, to evaluate the use of our System and to provide online reports, which show the activities on our Systems, and to provide other services concerning the use of our Internet site for us. Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our System. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements. The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our System by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties. The data subject may, as stated above, prevent the setting of cookies through our System at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs. In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this System, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons. Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/. 13. Data protection provisions about the application and use of Google Remarketing On this System, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise's Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users. The operating company of the Google Remarketing services is the Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other Systems, which are based on individual needs and matched to the interests of Internet users. Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our System if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behavior of the user, which Google uses, inter alia, for the insertion of interest relevant advertising. The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties. The data subject may, as stated above, prevent the setting of cookies through our System at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs. In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject. Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/. 14. Data protection provisions about the application and use of Google-AdWords On this System, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google's search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords. The operating company of Google AdWords is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. The purpose of Google AdWords is the promotion of our System by the inclusion of relevant advertising on the Systems of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our System. If a data subject reaches our System via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our System. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our System generated sales, that is, executed or canceled a sale of goods. The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our System. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject. The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties. The data subject may, at any time, prevent the setting of cookies by our System, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs. The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings. Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/. 15. Data protection provisions about the application and use of Node.js On the System, the controller has integrated Node.js plug-ins, which provides additional features to the operator of a System based on Node.js. Node.js is an open-source, cross-platform, back-end JavaScript runtime environment that runs on a JavaScript Engine (i.e. V8 engine) and executes JavaScript code outside a web browser, which was designed to build scalable network applications. Node.js lets developers use JavaScript to write command line tools and for server-side scripting, running scripts server-side to produce dynamic web page content before the page is sent to the user's web browser. Consequently, Node.js represents a "JavaScript everywhere" paradigm, unifying web-application development around a single programming language, rather than different languages for server-side and client-side scripts. Node.js has an event-driven architecture capable of asynchronous I/O. These design choices aim to optimize throughput and scalability in web applications with many input/output operations, as well as for real-time Web applications (e.g., real-time communication programs and browser games). The Node.js distributed development project was previously governed by the Node.js Foundation, and has now merged with the JS Foundation to form the OpenJS Foundation, which is facilitated by the Linux Foundation's Collaborative Projects program. The operating company of Node.js, the OpenJS Foundation, is located at 548 Market St. PMB 57274. San Francisco, CA 94104. OpenJS Foundation and their third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on their site and across third party sites or online services. OpenJS may combine this information with other information they collect about users. The applicable privacy policy provisions of OpenJS Foundation may be accessed under https://openjsf.org/wp-content/uploads/sites/84/2021/04/OpenJS-Foundation-Privacy-Policy-2019-11-15.pdf, and the cookies policy at https://www.linuxfoundation.org/cookies/. 16. Data protection provisions about the application and use of REACT.js On the System, the controller has integrated Node.js plug-ins, which provides additional features to the operator of a System based on React.js. React.js is a free and open-source front-end JavaScript library for building user interfaces based on UI components. React can be used as a base in the development of single-page, mobile, or server-rendered applications with frameworks like Next.js. However, React is only concerned with state management and rendering that state to the DOM, so creating React applications usually requires the use of additional libraries for routing, as well as certain client-side functionality. The operating company of React.js, Meta Platforms Inc (formerly Facebook), is located at 1 Hacker Way Menlo Park, California 94025. 17. Data protection provisions about the application and use of Objective C On the Apple Store, the controller has integrated Objective-C plug-ins, which provides additional features to the operator of an App based on Objective-C. The Objective-C is a general-purpose, object-oriented programming language that adds Smalltalk-style messaging to the C programming language. It was developed for non-Apple operating systems or that are not dependent on Apple's APIs. The operating company of Objective-C, Apple Inc, is located at 548 Market St. PMB 57274. San Francisco, CA 94104. Applicable information about Objective-C may be accessed under https://developer.apple.com/library/archive/documentation/Cocoa/Conceptual/ProgrammingWithObjectiveC/Introduction/Introduction.html. 18. Data protection provisions about the application and use of Java On the Apple Store, the controller has integrated Java plug-ins for Android operating system, which provides additional features to the operator of an App based on Java. Java is a high-level, class-based, object-oriented programming language that is designed to have as few implementation dependencies as possible. It is a general-purpose programming language intended to let programmers write once, run anywhere (WORA) meaning that compiled Java code can run on all platforms that support Java without the need to recompile. The operating company of Java, Oracle, is located at 2300 Oracle Way, Austin, Texas, U.S. 78710. 19. Payment system: Data protection provisions about the use of PayMe as a payment processor On this System, the controller has integrated components of PayMe. PayMe is an online payment service provider. PayMe obtains your personal data while you process your payment with us. The operating company of PayMe is PayMe Ltd, reg. No, 515033553, Address 18 Tozeret Haaretz, Tel-Aviv, Israel. support@paymeservice.com. When you make payments or conduct transactions, PayMe will receive your transaction information. The information will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The payment method information will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you when you make a transaction, and you may also provide your name, email, billing or shipping address and in some cases your transaction history to authenticate you. When PayMe conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to us, we will receive personal data from you (and your device) and about you either directly or through business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. PayMe fraud monitoring, detection and prevention services may collect personal data about you and use technology to help us assess the risk associated with an attempted transaction by you with a PayMe User. PayMe declares not to use, share, rent or sell your personal data for interest-based advertising, marketers or unaffiliated third parties. They share your Personal Data with: a. Trusted entities, to provide their services and for internal administration purposes, such as the sub payment processor: Isracard Ltd., Reg. No. 510706153, Address 40 Hamasger, Tel-Aviv, Israel. Customer services: IBINL@ISRACARD.CO.IL. +972-3-6364666. b. With a limited number of their service providers that provide services on their behalf, such as identity verification services, System hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. PayMe authorises such service providers to use or disclose the Personal Data only as necessary to perform services on their behalf or comply with legal requirements. PayMe require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on their behalf. PayMe service providers are predominantly located in the European Union and the United States of America. c. Business partners. PayMe shares Personal Data with third party business partners when this is necessary to provide their Services to their Users. Examples of third parties to whom they may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when they provide payment processing services, and the professional services firms that they partner with to deliver PayMe Atlas. d. PayMe Users and third parties authorised by their Users. They share Personal Data with Users as necessary to maintain a User account and provide the Services. We share data with parties directly authorized by a User to receive Personal Data, such as when a User authorises a third-party application provider to access the User's PayMe account using PayMe Connect. The use of Personal Data by an authorized third party is subject to the third party's privacy policy. e. Corporate transactions. In the event that PayMe enter into, or intend to enter into, a transaction that alters the structure of their business, such as a reorganisation, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of their business, assets or stock, they may share Personal Data with third parties in connection with such transaction. Any other entity which buys them or part of their business will have the right to continue to use your Personal Data, but only in the manner set out in their Privacy Policy unless you agree otherwise. f. Compliance and harm prevention. PayMe share Personal Data as they believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce contractual rights; (iii) to protect the rights, privacy, safety and property of PayMe, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence. PayMe declares to make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. Such as to maintain organisational, technical and administrative measures designed to protect Personal Data within their organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with PayMe is no longer secure (for example, if you feel that the security of your account has been compromised), please contact PayMe and us immediately. PayMe retain your Personal Data as long as they are providing their services to you. They retain Personal Data after they cease providing services directly or indirectly to you, even if you close your PayMe account or complete a transaction with a PayMe User, to the extent necessary to comply with their legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. They also retain Personal Data to comply with their tax, accounting, and financial reporting obligations, where they are required to retain the data by their contractual commitments to our financial partners, and where data retention is mandated by the payment methods that they support. Where they retain data, they do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Personal Data may be stored and processed in any country where PayMe have operations or where they engage service providers. They may transfer Personal Data that they maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, PayMe will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data. The applicable data protection provisions of PayMe (in Hebrew) may be retrieved under https://cdn.paymeservice.com/ng/payme_privacy.pdf 20. Accounting system: Data protection provisions about the use of iCount as an accounting processor On this System, the controller has integrated components of iCount. iCount is an online business management service provider, who will provide accounting services on this System. iCount obtains your personal data while you process your payments with us. The operating company of iCount, Icount Systems Ltd., an Israeli company reg. No. 513947119, Address 49 Hasivim Petach Tikva, Israel. When you make payments or conduct transactions, ICount will receive your transaction information. The information will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and services purchases. Different iCount methods may require the collection of different categories of information. The iCount method information will depend upon the iCount method that you choose to use from the list of available iCount methods that are offered to you when you make a transaction, and you may also provide your name, email, billing or shipping address and in some cases your transaction history to authenticate you. When ICount conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to us, we will receive personal data from you (and your device) and about you either directly or through business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. ICount fraud monitoring, detection and prevention services may collect personal data about you and use technology to help us assess the risk associated with an attempted transaction by you with a ICount User. ICount declares not to use, share, rent or sell your personal data for interest-based advertising, marketers or unaffiliated third parties. 21. Legal basis for the processing Art. 6(1) lit. a CCPA, GDPR or Israeli Privacy Act, as the case may be according to the place of the data subject using the web site, serve as the legal basis for processing operations for which we obtain consent for a specific processing purpose. 22. The legitimate interests pursued by the controller or by a third party Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders. 23. Period for which the personal data will be stored We retain personal data as long as we provide services to you. We retain personal data after we cease providing services directly or indirectly to you, even if you close your account or complete a transaction with us, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of complying with our tax, accounting, and financial reporting obligations, we are required to retain the data by our contractual commitments to our financial partners and suppliers, and where data retention is mandated by the payment methods and supplying services or goods methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. 24. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data. 25. Existence of automated decision-making As a responsible company, we do not use automatic decision-making or profiling. This Privacy Policy has been generated by the Privacy Policy Generator of the External Data Protection Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW and with the help of the Privacy Policy Generator and the Online Privacy Policy Generator. Legal examination by Yariv Kedem, Attorneys at Law.
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