EX.CO Privacy Policy

Last Revised: November 7th, 2019

 

Introduction

Hi there!

Playbuzz Ltd. (“we“, “us“, “EX.CO“) prepared this Privacy Policy and Cookie Policy (which is incorporated herein) to explain to you how and why we collect Personal Information (meaning, any information which identifies or may potentially identify you with reasonable means) about you when you are using our Platform.

The Privacy Policy and Cookie Policy are a part of the EX.CO Terms and Channels Terms, which are incorporated therein by references. The definitions, which appear in this document, shall have the meaning ascribed to them in our EX.CO Terms and Channels Terms.

We encourage you to review the following information carefully.

 

From whom do we collect Personal Information?

This Privacy Policy applies to EX.CO’s collection, use, and disclosure of the personal information of the following categories of individuals:

·       Website Visitors – individuals who visit our Website (https://www.EX.CO) and who may volunteer certain contact data (such as their email address) to receive communications from EX.CO.

·       Customers – those who register on their own or on behalf of an entity or organization to use any product(s) or service(s) within EX.CO’s Platform, including administrators of an EX.CO Account. For the purposes of this Privacy Policy, “Services” shall refer to all product(s), service(s) or offering(s) made available by EX.CO.

·       End Users – individuals who visit our Customers’ websites and whose information we process (on behalf of our Customers) in order to provide the Services to our Customers pursuant to our agreements with them (“End Users”). All personal data about End Users will be solely collected on behalf of our Customers. EX.CO may use the data collected for analytics and customization of ads only in an aggregated and anonymized form. EX.CO will not collect or process any Sensitive Data of End Users.

 

What kinds of information do we collect?

Depending on which features of the Platform you use, we collect different kinds of information (including Personal Information) about or from you. This Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests, as well as for compliance with regulatory obligations to which we are subject. If this information will not be provided, you may not be able to use our Platform (such as opening an EX.CO Account), or certain features of our Platform. In certain instances, we will obtain your consent to the collection of your Personal Information, as appropriate (in which case, you can revoke your consent at any time by approaching us).

 

From Website Visitors

·       Name, email address, and other contact information – we ask for and – at your option – collect your contact data (such as name and email address) from you when you submit web forms on our Website, including opportunities to sign up for and agree to receive email communications from us. We also may ask you to submit such Personal Information if you choose to use interactive features of the Website, including participation in surveys, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law.

·       Log Files – just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Website, we may gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences.

·       Cookies and Other Tracking Technologies – we may use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Website and assisting us in our marketing efforts. Note that if you disable cookies entirely, EX.CO’s Website may not function properly. We may also use cookies and similar technologies to provide you advertising on third-party sites based upon your browsing activities and interests.

 

From Customers

·       Customer Account Information – when you register for an EX.CO Account, we collect your email address, name and other contact data. We may also ask you to enter your website domain in order to provide our Services. We refer to this information as “Customer Information” for the purposes of this Privacy Policy. Customer Information is required to identify you as a Customer and permit you to access your EX.CO Account(s). By voluntarily providing us with such Customer Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us. If you register to our Platform through a social network platform (for example Google), you will provide us access to any information you made available on that platform (depending on your privacy settings) and any additional information that you specifically consent to provide us with.

·       Payment Information – when you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we (or third party service providers) will collect your card information and billing address, although we do not store full credit card numbers or personal account numbers.

·       Technical information – this includes certain technical Personal Information that is recorded when you use our Platform and/or our services. This information may include but is not limited to IP addresses, unique and persistent device identifiers, WiFi information, operating system and device information, system configuration information, and other information about traffic to and from Customers’ websites.

 

From End Users

·       Contact Information – we collect information from lead generation forms, filled by End Users, on behalf of our Customers. The data collected may vary and may include personal information. We will not collect any sensitive data on End users.

·       Technical Information – we collect End Users’ information when they use our Customers’ websites, web applications, and APIs. This information may include but is not limited to IP addresses, unique and persistent device identifiers, WiFi information, operating system and device information, system configuration information, and other information about traffic to and from Customers’ websites (collectively, “Log Data”). We collect and use Log Data to operate in performance of our obligations under our Customer agreements.

·       Data collected from End Users will be used solely on behalf of our Customers, who serve as Data Controllers. EX.CO may process the data collected on its own behalf only on and aggregated and anonymized basis for research, analytics, improvement of our Platform and customization of ads.

If we combine Personal Information with anonymous information about you, the combined information will be treated as Personal Information for as long as it remains combined.

 

Tracking technologies

When you visit or access our Platform (including when you interact or engage with our Embedded Items), we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags and other technologies (“Tracking Technologies“).

These Tracking Technologies allow us and third parties to automatically collect information about you (including your Personal Information, such as your IP address or other unique identifiers, your device’s location or hashed email address) and your online behavior, as well as your device, in order to enhance your navigation on our Platform, improve our Platform’s performance and customize your experience on our Platform, as well as for behavioral advertising and fraud prevention purposes. We also use this information to collect statistics about the usage of our Platform, perform analytics and administer services to our Users, Customers and partners. To learn more please visit our Cookie Policy.

 

How do we use the information we collect?

·       Managing user registration – if you have registered for an EX.CO Account, we process your Personal Data by managing your user account for the purpose of performing our obligations under our contract with you according to the applicable terms of service.

·       Billing purposes – if you registered for an EX.CO Account, we (or third party service providers) will process your billing information, as provided by you, in order to charge our Services. We will occasionally send you communications of a transactional nature including billing related matters like receipts.

·       Administration and internal records – we may use data collected from our Customers for administration and internal record keeping purposes, including but not limited to accounting purposes, maintaining Customer databases, billing etc.

·       Provision of our services – we work hard to provide you with the best user experience on our Platform. In order to do so, we use all information that we have (including Personal Information) to create a personalized experience for our users and to improve our Platform.

·       Communications and updates – we may use your Personal Information to communicate with you, for example, we may use your email address to respond to your queries or feedback, inform you about our new features, or send you reminders to complete activities that you’ve started on our Platform or remind you of your password (if you’ve forgotten it). We may also use your Personal Information to let you know about our policies or important notifications and updates about our Platform.

·       Analytics, surveys and research – we are always trying to think of new and exciting features for our Users. From time to time, we conduct surveys or test features in our Platform, and analyze the information we have to develop, evaluate and improve these features.

·       Marketing – we may use your Personal Information to alert you about upcoming features or provide you notifications concerning certain features on our Platform. We may also send you promotional materials concerning our partners’ products, which we believe may interest you. You may choose not to receive our promotional or marketing emails at any time, by clicking on the unsubscribe link in the emails that you receive from us. Please note that even if you unsubscribe from our newsletter, we may continue to send you service-related updates or notifications.

·       Protecting our interests – we use your Personal Information when we believe it’s necessary in order to take precautions against liabilities, investigations and to defend ourselves against any third party claims or allegations, protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of EX.CO, its Users and/or partners.

·       Enforcing of policies – we use your Personal Information in order to enforce our policies, including but not limited to our EX.CO Terms, Channels Terms, and/or any other obligations under an agreement between you and EX.CO.

·       Compliance with legal and regulatory requirements – we also use your Personal Information to investigate and prevent violations, and as may be required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

·       Displaying personalized advertisements and content – we process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our Website or, where necessary, to the extent you have provided your prior consent.

 

With whom do we share the information that we collect?

·       Internal concerned parties – we may share your information with companies in our group, as well as our employees, in order to provide you with our services

·       Service providers – we may share your Personal Information with our service providers, such as payment processors, storage providers (such as AWS), marketing affiliates (who assist us with carrying our marketing campaigns, such as email campaigns), our fraud detection tools, and our analytics providers who help us provide you with our service.

·       Legal and regulatory entities – we may disclose information in case we believe, in good faith, that such disclosure is necessary in order to enforce our policies (including our EX.CO Terms and Channels Terms) take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, protect the security or integrity of the Platform and protect the rights and property of EX.CO, its users and/or partners. We may also disclose your Personal Information where requested by legal or regulatory authorities having control or jurisdiction over us, you or our partners.

·       Mergers and acquisitions – we may share or transfer your Personal Information if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your information in accordance with the terms of this Privacy Policy.

·       Professional advisers – in individual instances, we may share Personal Information with professional advisers acting as processors or controllers including lawyers, bankers, auditors, insurers and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.

 

International data transfer

Please note that our businesses, as well as our trusted partners and service providers, are located around the world. Any information that we collect (including your Personal Information) is stored and processed in various jurisdictions around the world (including in the United States), for the purposes detailed in this Privacy Policy. Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

 

Children privacy

We do not knowingly collect or solicit Personal Information from anyone under the minimum age for providing consent in the jurisdiction they reside in (“Age of Consent“) or knowingly allow such persons to register as Users. By accessing or using our Platform, you certify to us that you are at the Age of Consent. In the event that we learn that we have collected Personal Information from a child under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about a child under the Age of Consent, then please contact us at support@ex.co.

 

Information collected by third parties

Some of our third party partners may obtain Personal Information from you if you voluntarily submit such information. We are not responsible for any information collected by such third parties, or their privacy practices. Therefore, you should always review their privacy practices carefully before providing Personal Information to such third parties.

When you make purchases through our Platform, we process you payments through a third-party payment processor. In these instances, the third party application may collect certain Personal and Financial Information from you to process a payment on behalf of EX.CO, including your name, email address, address, credit card number and other billing information in which case the use and storage of your personal and financial information is governed by the third party application’s terms and condition and privacy policy.

 

User Rights

If you reside in the EU (or in a jurisdiction that affords you with the below rights), you may request to:

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. If you ever decide to exercise any of the above rights or to terminate your EX.CO Account, you may do so by emailing us at support@ex.co.

If you terminate your EX.CO Account, any Personal Information that you have provided us will no longer be accessible via your EX.CO Account.

 

Retention

We will retain your Personal Information for as long as necessary to provide our services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

 

Protecting your information

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information.

Your EX.CO Account information is protected by a password for your privacy and security. You need to help us prevent unauthorized access to your EX.CO Account by protecting your password appropriately and limiting access to your account by signing off after you have finished accessing your EX.CO Account. You will be solely responsible for keeping your password confidential and for all use of your password and your EX.CO Account, including any unauthorized use.

While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security and privacy of your Personal Information or other content you transmit using the Platform, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the Personal Information you choose to disclose.

 

Changes to our Privacy Policy

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Platform or we will send you an e-mail regarding such changes to the e-mail address that you volunteered. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Platform after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

 

Have any questions or comments? Contact us!

If you have any comments or questions about our Privacy Policy, you can always contact our Data Protection Officer, either at dpo@ex.co or by postal mail:

Playbuzz Ltd.

Attn: Data Protection Officer

5 Aluf Kalman Magen St.

Building A, 1st Floor,

Tel Aviv, 6107077,

Israel


You may also approach our representative at the UK:

Playbuzz UK Limited

Formal Address: 37 Broadhurst Gardens,

London, NW6 3QT, UK