Komoona’s Privacy Policy

Komoona Ltd. (“Komoona“, “Company” “we” or “us“) respects the privacy of the visitors and/or users of its website at http://www.komoona.com/ (including its subdomains) (collectively, the “Site“) (“User” or “you”) and is committed to protect the personal information that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site and/or open an Account for our Service. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at [http://komoona.com/terms-of-use] (“TOU“), into which this Privacy Policy is incorporated by reference.
  1. Your Consent (PLEASE READ CAREFULLY!)
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR BY USING THE SERVICE, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY“), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE SITE OR SERVICE. FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US.
  1. Which information we may collect on our Users?
We may collect two types of data and information from our Users:
  1. Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the Site. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Site, type of operating system, User’s ‘click-stream’ or searches on the Site, type and version of browser, keyboard language, screen resolution, etc.
  2. Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
    • Users of the Site automatically provide their IP address mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.
    • When opening an Account, you may be required to provide the following details: full name, e-mail address and a password. Once your contact details received by us, our representative will contact you to complete the registration process.  Our representative may collect additional information from you.
    • In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User (e.g. in the contact or payment-details forms on the Site) or during the business cooperation.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists. We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the TOU and the Privacy Policy.
  1. How Do We Collect Information on Our Users?
There are a few methods that we use:
  1. We collect information through your entry and use of the Site or Service. In other words, when you are using the Site and Service we are aware of it and may gather, collect and store the information relating to such usage.
  2. We collect information which you decide to provide us voluntarily. For example, we collect Personal information when you contact us through the contact form or when you open an Account.
We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below
  1. What are the Purposes of the Collection of Information?
Non-personal Information is collected in order to:
  • Use it for statistical and research purposes and for customization and improvement of our Site and Services.
  • Enhance the User’s experience while using the Site and Services.
Personal Information is collected in order to:  
  • Provide and personalize our Services to our Users.
  • Verify the User’s identity when he/she signs in through his/her Account.
  • Provide Users with updated information regarding our products and services.
  • Be able to contact Users for the purpose of providing them with technical assistance and support.
  • Determine general geolocation information (i.e., country) from which the User’s computer is connected to the Internet in order for us to know the general location of our Site’s Users as well as in order to safeguard our Site.
  • Enable payment through third party Online Payment Processors. Please note that we do not collect credit card or other financial information.
  1. Sharing Information with Third Parties
Komoona will not share any Personal Information it collects with any third party, other than in the following circumstances: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the TOU, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (e) to protect the rights, property, or personal safety of the Company, its Users or the general public; (f) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of the Company, so long as such acquirer maintains the same privacy terms hereunder; or (g) pursuant to your explicit approval prior to the disclosure. Note, that we collect, hold and/or manage Personal Information through Komoona’s authorized third party vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction. For avoidance of doubt, Komoona may transfer and disclose Non-personal Information to third parties at its discretion, including without limitation for statistical, analytical and research purposes and for customization, development and improvement of our Site and Service.
  1. What is our Privacy Policy with respect to your End-Users?
In order to provide you with our Services and serve Ads to your Properties, and in order to constantly improve our Services, we and our authorized third party advertisers may collect, use and disclose certain data related to the end-users of your Properties (the “End-User Data” and the “End Users“, respectively).
  • Which information we may collect on End-Users?
End User Data consists of the following types of information:
  • End-Users Non-personal Information: Non-personal Information is any unconcealed information which does not enable identification of an individual End-User. Non-personal Information is available to us and may be available to our authorized third party advertisers while End-Users are accessing or using your Properties. Non-personal Information which is being gathered may consist of technical information, behavioral information or aggregated information, and may contain, among other things: technical data, e.g. type of operating system and configuration, screen resolution, screen density, software version, hardware type, usage patterns and other statistical data, the time the End-Users were engaged with the Ads on your Properties, etc.
  • End-Users Personal Information: We and our authorized third party advertisers may collect the following Personal Information: End-User’s IP address, Device ID, geo-location (country, region, city) and/or other behavioral information related to a particular End-User. It should be noted, however, that such information is not used by us in order to personally identify a specific End-User but rather for technical and statistical purposes, as described below.
  • How Do We Collect End User Data? We and our authorized third party advertisers may collect End-User Data if you provide it to us and/or once you serve Ads (and/or Ad serving scripts) to your Properties. The End-User Data may be collected by use of various tracking technologies. We and our authorized third party advertisers may gather, collect and store the information either independently or through the help of our authorized third-party service providers as detailed below.
  • What are the Purposes of the Collection of End-User Data? We and our authorized third party advertisers may use the End-User Data in order to provide you the Services, i.e., for the purpose of displaying Ads of our third party advertisers on your Properties. For example, we will collect Personal Information in order to determine geo-location information from which the End-User is connected to the Internet in order to serve Ads through the Service based on such End User’s location. In addition, we and our authorized third party advertisers will collect End-User Data in order to (i) create statistics and other aggregate information and analysis with respect to your End User’s engagement with Ads which are served to the Properties through the Service; (ii) use it for statistical, analytical and research purposes and for customization, developing and improvement of our Services; (iii) for general campaign performance in order to report to our authorized advertisers or SSPs; (iv) to determine the amounts to bid, pay or offer for impressions or units of ad-inventory; and/or (v) detect fraudulent activities that occur while your End Users are engaging with Ads on your Properties.
IT SHOULD BE NOTED, HOWEVER, THAT SUCH END USER DATA IS NOT USED BY US IN ORDER TO PERSONALLY IDENTIFY A SPECIFIC END-USER BUT RATHER FOR TECHNICAL AND STATISTICAL PURPOSES, AS DESCRIBED IN THIS SECTION.
  • Sharing End User Data with Third Parties. In addition to the sharing of End Users Data in order to fulfill the purposes mentioned above, we may share your End User’s Personal Information in the cases specified in Section 5 above.
  • Deletion or Modification of End User Data. Since we have no direct relationship with your individual End-Users and we do not send communications to your End-Users, you hereby agree to handle all End-User’s requests with respect to deletion and modifications of their information. End-Users who seek access to their Personal Information, or who wish to correct, amend, delete inaccurate information or withdraw consent for further use of their Personal Information should direct their request to you.   If you are unable to handle such a request and only we possess the ability or power to solve your End-User’s request or issue, please forward that request to us and provide us with the necessary instructions and we will make reasonable efforts to solve the issue pursuant to any applicable privacy laws.    Unless you instruct us otherwise, we may retain your End-Users’ Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws. Aggregated and/or anonymous data may remain on our servers indefinitely.
  • Children/Minors End User Data. You agree that you will not use the Services in connection with any Properties directed to Minors. The term “Minor” shall mean a Child as such term is defined under the Children’s Online Privacy Protection Act of 1998 and the rules promulgated by the Federal Trade Commission (FTC) under that Act, including but not limited to the Children’s Online Privacy Protection Rule 16 C.F.R. Part 312 (the “COPPA“) or any other under-age individual as defined by applicable children protection legislation in any relevant jurisdiction. You will (i) notify Komoona in writing of any Properties which are or may be considered as a “Child Property” under the COPPA, and (ii) to the extent required by applicable laws, implement reasonable commercial means within the Properties for identifying Minors when the Properties are not primarily directed at children under such age; all in order to enable Komoona to block collection of information from Minors. If you learn that any information transferred to us via the Services includes Personal Information collected from Minors, please inform us immediately and we will delete that information as quickly as possible.
  • Tracking Technologies with respect to End Users. When Ads (and/or Ad serving scripts) are served to your Properties via the Services, Komoona and/or third party advertisers or SSPs may use industry-wide tracking technologies (e.g., cookies, web beacons, etc.) which store certain information on the Properties (“Technologies“) and which allow us or such third parties to collect certain data for the purpose of serving Ads through the use of our Services (including without limitation, serving Ads that may be of interest to End Users). As abovestated, Komoona will not use the Technologies in order to personally identify a specific End User. In each case, End Users will be subject to the third party advertisers’ privacy policies.
  • Behavioral Advertising. You should notify your End Users that our authorized third party advertisers may serve you behavioral advertisements. You should include a conspicuous mechanism by which your End Users may opt out of such online behavioral advertising.
  1. Deletion or Modification of your Personal Information
In any event, if for any reason you (or any person) wish to delete or modify Personal Information, you can do so within your Account. Otherwise, please send us an e-mail with adequate detail of your request to: support@komoona.com and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws. Aggregated and/or anonymous information derived from your use of the Site or Services may remain on our servers indefinitely.
  1. Minors
The Site is intended for Users over the age of eighteen (18). Komoona does not intend and does not knowingly collect Personal Information from children under the age of thirteen (13) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the Site. If we learn that we collected Personal Information from children under the age of thirteen (13) we will delete that information as quickly as possible. Please contact Komoona at support@komoona.com  if you have reasons to suspect that Komoona collected Personal Information from children under the age of thirteen (13) and will delete that information as quickly as possible. It is hereby clarified that the documents you provide us access to may include information regarding children under the age of thirteen (13) only in the event that the legal guardian of such child has agreed to such use, all as required under any applicable laws.
  1. Security
We take reasonable measures to maintain the security and integrity of our Site and Services and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. The Personal Information is hosted with reputable cloud-hosting vendors which provide advanced strict security standards (both physical and logical). In addition, we employ highly secure services design and implementation using encryption and architectures mechanisms. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guar antee that unauthorized access or use will never occur. KOMOONA SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.    
  1. Third Party Service Providers
In order to provide the Site and/or Services we may be using third party service providers, who may collect, store and/or process the information detailed herein. Komoona uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Please note that we do not control such third party service providers.
  1. Links to Third Party Websites
Certain links provided herein permit our Users to leave this Site and enter non-Komoona sites or services (including but not limited to Facebook’s “Share” and “Like” buttons available in our Site, Twitter and Google+). Komoona is not responsible or liable for such linked sites and services’ privacy practices and/or any other practices. Your access to, use of and reliance upon any such sites, services and content and your dealings with such third parties are at your sole risk and expense. Those linked sites and services are provided solely as a convenience to you. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.
  1. Cookies and Other Tracking Technologies
When you access or use the Site, we or our third party service providers may use industry-wide technologies such as “cookies” or other similar technologies which store certain information on your computer or device (“Cookies“), which will allow us to enable automatic activation of certain features and make your experience much more convenient and effortless. We or our authorized third party service providers may use both session cookies (which expire once you close the Site) and persistent cookies (which stay on your system until you delete them). It is easy to disable or delete Cookies. Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you disable or erase cookies, your online experience may be limited. Cookies usually store only a Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc. Komoona does not control such third party service providers.
  1. International Data Transfer
In order to provide the Site and Service, we may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.
  1. Direct Marketing
You hereby agree that we may use the contact details you provided us for customer support purposes, as well as to inform you regarding our products and services. You may withdraw your consent by following the instructions for removing yourself from the mailing list which are available in the message transmitted to you.
  1. Changes to the Privacy Policy
The terms of this Privacy Policy will govern the use of the Site and any information collected therein. Komoona reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this policy on the homepage of the Site and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.
  1. Got any Questions?
If you have any questions or comments concerning this Privacy Policy, you are most welcome to send us an email to the following address: support@komoona.com.