We, at Convo Media Inc. (“Convo Media”) are committed to respecting our customers’ privacy, protecting their personal information and making sure it is used properly by us.
The use of the Services constitutes consent to be bound by the terms of this Policy and you hereby agree and confirm that you will not have any claims or demands with respect to the Policy.
“Personal Information” means details which identify you or could be used to identify you, such as IP address etc.
“Non Personal Information” means information that does not personally identify you or your representative and does not reveal your specific identity as an individual and/or cannot be attributed to you, such as operation system name and version, browser name and version, device name and version, referring site, searched terms.
“GDPR” means the General Data Protection Regulation (EU) 2016/679, as amended from time to time.
“Services” means use of our products or services.
This Policy was originally written in English. If you are reading a translation and it conflicts with the English version, please note that the English version prevails.
3. THE PERSONAL INFORMATION THAT WE COLLECT
4. NON PERSONAL INFORMATION
We may collect Non-Personal Information in the following ways:
- a) The ways we collect Personal Information.
- b) Information that your browser sends when you use our Services (“Log Data”). This Log Data may include, but is not limited to, browser name and version, operation system name and version, statistic date, internet service provider (ISP) the webpage that you visited, the search term you typed and computer language.
- d) We may use GIFs in order to collect information. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.
- e) We may use automated devices and applications to evaluate usage of our Services. We use these tools to help us improve our Services, performance and user experience. We may also engage third parties to track and analyze Service data or provide other services on our behalf. Such third parties may combine the information that we provide about you with other information that they have collected from other sources. This Policy does not cover such third parties’ use of the data and such use is governed by such third parties’ privacy policies.
By using the Services and when you provide us with Non Personal Information, you hereby agree and consent that Non Personal Information will be considered as non-confidential, non-proprietary, and unprotected.
5. HOW WE USE PERSONAL INFORMATION
Personal Information is used for the following primary purposes (as may be updated from time to time): to (i) provide the Services; (ii) monitor and analyze use of the Services and study and analyze the functionality of the Services; (iii) for the technical administration and troubleshooting of the Services and to provide support and maintain the Services, (iv) to search for fraudulent traffic sources; (v) provide service announcements and market the Services; (vi) enforce our Terms of Service, policies and other contractual arrangements, to comply with court orders and warrants, and prevent misuse of the Services, and to take any action in any legal dispute and proceeding.; (vii) better understand your needs both on an aggregated and individualized basis in order to improve and continue developing our Services; (viii) communicate with you and contact you to obtain feedback from you regarding the Services; (ix) disclose to third party vendors, service providers, contractors or agents who perform functions on our behalf with respect to the Services; (x) enable the Service’s tools and features, and (xi) as otherwise authorized by you.
6. HOW WE USE NON PERSONAL INFORMATION
We may use information that is Non Personal Information for the same purposes we use Personal Information (where applicable) and in addition in order to (i) compile anonymous or aggregate information, (ii) disclose to third party vendors, service providers, contractors or agents who perform tasks on our behalf in connection with the Services, (iii) monitor and analyze use of the Services and for the technical administration and troubleshooting of the Services, and (iv) provide us with statistical data.
We use anonymous, statistical or aggregated information, which may be based on extracts of your Personal Information, for legitimate business purposes including for testing, development, improvement, control and operation of the Services. We may share such information with third parties on our behalf. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you. We will share your Personal Information only subject to the terms of this Policy, or subject to your prior informed consent.
7. THE LEGAL BASIS FOR USE OF INFORMATION
We will only process your Personal Information where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use your Personal information. In almost all cases the legal basis will be:
- a) To provide the Services and otherwise perform our agreement we have with you.
- b) Because you consented to us using the Personal Information for a particular purpose.
More information on the basis of processing:
- a) Processing Personal Information is required for performing an agreement to which you are a party and rendering the Services or in order to take steps at your request before entering an agreement, for example: (1) we collect Personal Information in order to check for fraudulent traffic sources.
- b) It is hereby clarified that the legal bases detailed above are the legal bases for actions to process Personal Data, carried out by us in accordance with the GDPR. If processing of Personal Data is subject to other Applicable Laws, then the legal basis for processing Personal Data may differ according to those Applicable Laws.
8. SHARING INFORMATION WITH OTHERS
Convo Media does not rent, sell, or share any information about you with any third-parties.
However, Convo Media may disclose your Personal Information if Convo Media believes such action is necessary to:
- (a) comply with the law or legal process served on Convo Media;
- (b) protect and defend the rights or property of Convo Media (including the enforcement of our agreements); or
- (c) Act in urgent circumstances to protect the personal safety of users of Convo Media services or members of the public.
- (d) We may need to disclose Personal Information in response to lawful requests by public authorities or law enforcement officials, including meeting national security or law enforcement requirements. We cooperate with government and law enforcement officials to enforce and comply with the law.
- (e) Additionally, a merger, acquisition or any other structural change may require us to transfer your Personal Information to another entity, provided that the receiving entity will comply with this Policy.
9. TRANSFER OF DATA OUTSIDE YOUR TERRITORY
We may store, process or maintain information in various sites worldwide, including through cloud based service providers worldwide. Where the GDPR applies and we transfer Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:
- a) the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data (Israel is an approved country);
- b) the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
- c) where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
- d) in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.
You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described the Section “CONTACT US” below.
If you are located in a jurisdiction where transfer of your Personal Data to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer or the storage, processing or maintenance of the information in other jurisdictions by using the service.
10. YOUR RIGHTS
In all of the above cases in which we collect, use or store your Personal Information, you may have the following rights and, in most cases, you can exercise them free of charge.
At any time, you may contact us at: email@example.com and request to know what Personal Data we keep about you. We will make good-faith efforts to locate the data that you request to access.
Under your right of access, you may obtain confirmation from us of whether we are processing Personal Data related to you, receive a copy of that data, so that you could verify its accuracy and the lawfulness of its processing, request the correction, amendment or deletion of the data if it is inaccurate, incomplete, outdated or processed in violation of applicable law.
However, we may retain certain information as deemed required by us in accordance with applicable laws, or for legitimate business reasons, for the duration as required under applicable laws.
In addition, we may delete any Personal Data pursuant to our policies, as in effect from time to time.
11. RESPONSE TO REQUESTS
When you ask us to exercise any of your rights under this Policy and the applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Information related to others and to ask you questions to better understand the nature and scope of data that you request to access.
We may redact from the data which we will make available to you, any Personal Information related to others.
12. INFORMATION SECURITY
We take the safeguarding of the Personal and Non Personal Information very seriously, and use a variety of systems, applications and procedures to protect the information from loss, theft, damage or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict access to the information. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
You should take steps to protect against unauthorized access to Personal Information stored on your premises as well as defining limited access rights to such information on a need to know basis.
If you receive an e-mail asking you to update your information with respect to the Services, do not reply and please contact us at firstname.lastname@example.org
13. DATA RETENTION
We retain different types of information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law. We may retain Personal Information for as long as necessary to support the collection and the use purposes of this Policy and for other legitimate business purposes, For example, for storing information for documentation, for managing internet security for legal proceeding and for text purposes. We may store non-personal aggregate information without time limit. In any event as long as you use the services, we will retain information about you and your users, unless we are legally required to delete it, or if you seek to exercise your rights to delete the information.
14. OUR POLICY TOWARD CHILDREN
Our Sites are intended for general audiences over the age of 16 years old. We do not knowingly collect information from children under the age of 16 years old. IF YOU ARE NOT AT LEAST 16 YEARS OLD, DO NOT USE THE SERVICES.
From time to time, Convo Media may revise this Policy. Convo Media will post the revised Policy on the Site, so that users can always be aware of what information Convo Media collects, how the information is used and under what circumstances such information may be disclosed. Your continued use of the Services following such notice shall constitute your consent to any changes made and a waiver of any claim or demand in relation to such changes. If you do not agree to the new or different terms, you should not use and are free to discontinue using the Services.
16. CONTACT US
For further information about this Policy, please contact us at: email@example.com
We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact us and we will make good-faith efforts to address your concerns.
Copyright © 2019, Convo Media inc. . All rights reserved.
Last Updated: January 29, 2020