Privacy Policy

[Last Modified: January 1, 2020]

Vidazoo Ltd. (collectively with its affiliates and subsidiaries shall be referred to as “Vidazoo”, “we”, “us”, or “our”) is committed to your right to privacy. Protecting our users' privacy is a core value of Vidazoo, and we take precautions to ensure the protection of our users' personal data as well as to comply with applicable privacy and data protection legislation.

This privacy policy (“Privacy Policy” or “Policy”) which is incorporated by reference in our Terms and Conditions (“Terms”), governs the processing and transfer of data collected in connection with our website, available at: www.vidazoo.com, our software, products, platforms, technologies and services that we make available to different type of customers (respectively, “Site” and “Platform” and jointly, the “Services”). When we use the term Platform, we may refer to one or more of the following platforms: (a) our multi-screen video player technology; (b) our ad server and respective BI and analytic services and dashboards; or (c) our ad bidding and serving marketplace;

In order to provide the Services, we collect and use certain information about our customers (“Business Partners”) and users using any part of the Services (meaning Platform and Site’s visitors- shall be referred to herein as “users” and “Visitors” and collectively with our Business Partners as “you” or “your”). This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

In the event you are a California resident and the CCPA apply to you – please review our CCPA Privacy Notice, in order to be provided with the information you are entitled to under the CCPA.

HIGHLIGHTS:

· You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. Some of our Services however, may depend on providing us with certain Personal Data, as specified below.

· We have included below information about which Personal Data is collected and how we process and use your Personal Data, but before we would like to explain the lawful basis on which we do so: (1) when our Business Partners register to our Platform, we process their Personal Data in order to perform our contract with them; (2) when you access our Site or Services we may collect certain online identifiers which we have a legitimate interest in processing (for example for security purposes and fraud detection), some of this data is processed by our third party partners; (3) we may process Personal Data subject to your consent; or (4) where there is a legal obligation imposed on us or to protect our legal rights.

· Children (as defined under applicable law) are not permitted to use the Services or provide us with any Personal Data.

· You may be entitled under applicable law to request to have access, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled.

· We will share Personal Data with third parties in connection with the provision of the Services, or other limited circumstances as specified herein.

· If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please send us an email to: support@vidazoo.com (or as described below).

POLICY’S AMENDMENTS

We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the Site. The updated date of the Policy will be reflected in the “Last Modified” heading. In the event of material amendments, that will substantially affect our privacy practices or your rights, we will make best efforts to provide an applicable notification. Any amendments to the Policy will become effective immediately upon the display of the modified Policy. We recommend you to review this Policy periodically to ensure that you understand our most updated privacy practices.

TYPES OF DATA WE COLLECT

Non-Personal Data

During your interaction with our Services we may collect aggregated, non-personal non-identifiable information which may be made available or gathered via your access to and use of the Site or Platform (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data which is being collected may include your aggregated usage information and technical information transmitted by your device.

Personal Data

We may also collect from you, during your access or interaction with the Site or Services, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Persona Information”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below.

Type of Data

Purpose of Processing

Lawful Basis under the GDPR

Business Partner’s Account If you are our Business Partner, we may collect Personal Data that you are required to submit to us when you open an account with us. In which case, we will collect your email address of the entity on which behalf you are engaging with us and chosen password for accessing your account.

We will use this information to provide you with the Services you have requested, and designate your account in order to display the applicable information on your account dashboard. We will use your email address in order to send you needed information related to the Services and our business engagement.

In addition, we may send you marketing and promotional messages, offers and discounts. You are able to opt out unsubscribe through a designated link in the email that we will send or contacting us at: support@vidazoo.com.

Please note that if you choose to unsubscribe from direct marketing, we may still hold your account information and may contact you for updates regarding your use if the Services or any other relevant account information.

Performance of our contract.

Necessity of processing for the purposes of our legitimate interests.

Online Identifiers and Technical Data We will collect your IP address in the event you are a user interacting with our Platform or in the event you are our Site’s Visitor.

In addition, we may also collect “Technical Data” transmitted from your device (such as type, operating system type, version and language), your user agent, that includes the browser type, version and language from which you access the Platform or Site, approximate geographical location, the domain or URL of the website you browse in which the Platform is integrated and the Services are displayed or served; in which case, we do not store such URL, but our system will only use it on real time to make a decision about the type of content to display to you. Such information may be attributed to our Platform or Service ID that we generate for each type of Platform or to a general user ID that we generate for each user on the system and is a completely random identifier.

We use IP address and the Technical Data in order to provide our Platform related Services, user validation, fraud detection and to calculate payments.

In the event you are an end user interacting with our Platform (i.e., our media player implemented in our Business Partner’s digital assets), your IP address is retained separately from other data items with no ability to combine it.

In the event you are our Site’s Visitor, we may collect IP address and Technical Data for the purpose of operating and improving our Site, performance and analytic purposes.

Performance of a contract.

Necessity of processing for the purposes of our legitimate interests.

Where required under applicable law, we will require our Business Partners to obtain your consent

Contact Details

If you contact us in any means of communications, we make available, you may be required to provide us with certain information such as your name and email address.

We will use your contact details and may save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other service requested by you.

Performance of a contract.

Necessity of processing for the purposes of our legitimate interests

Recruitment If you are interested in working with us, you may voluntarily send us your CV by through the means of communications we make available on our Site.

In the event you send us your CV, note that, your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

Necessity of processing for the purposes of our legitimate interests.

Please note the following:

(i) we may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Site and Services, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.

(ii) We act as a Processor of certain Personal Data, as defined under the GDPR, such as users’ IP address on behalf of our Business Partners. We are also a Controller of certain Personal Data, such as our Business Partner’s data, or if individuals contact us or access our Site.

HOW WE COLLECT DATA

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

(i) automatically, including through the use of Cookies (as detailed below) and similar tracking technologies such as web beacons (used by us or by our Business Partners (i.e., advertisers)), tracking pixels, etc. These tracking technologies are used to gather the information described above about users that interact with the Platform or the Business Partner’s applicable content (i.e., ads, that shall be referred herein as “Business Partner Content”). Any interaction you make with such Business Partner Content is govern by the applicable providers’ policies, terms and conditions, so we advise you to refer to their privacy policies to learn more about their data collection and protection practices.

In addition, when a you visit our Site or interact with any of the Platforms Technical Data from your browser and IP address is automatically collected into a log file. This information includes your device’s IP address, user’s browser type, operating system, access times, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address. This log files are collected in statically and random data points and deleted shortly following our use for monitoring and debugging our Services.

(ii) when you voluntarily choose to provide us with information, i.e. when you contact us, register to our Services, etc., all as detailed in this Policy. Whenever technically possible and required under applicable law, we will ask for your consent to collect your Personal Data and offer you the choice to opt-out.

COOKIES AND SIMILAR TECHNOLOGIES

When you access or use the Site, or interact with our Services, we may use “cookies” (or similar technologies), which store certain information on your device (i.e., locally stored) and which will allow us to customize the Service and content as well as enhance your experience of the Services. The use of cookies is a standard industry-wide practice. A "cookie" is a small piece of information that a website or assigns and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes such as allowing you to navigate between pages efficiently and making the interaction between you and our Services quicker and easier, as well as to help customize your experience and for advertising purposes (including personalized advertising). You can find more information about cookies at www.allaboutcookies.org.

For more information about cookies and your controls in this regard, please review our Cookies Policy.

WITH WHOM WE SHARE INFORMATION

We will not share any Personal Data collected from you with third parties or any of our partners except in the following events:

(i) We pass along a page URL in which our Services are implemented and IP address to our third-party content and advertising partners, so they will be able to bid for content that best suit such web-page, as a part of our Services. In some cases when we buy media online, we may submit non-personal information that is cookie based. In those cases, non-personal parameter we provide to the media owner, may become personally identifiable when such media owner combines our parameters with its own existed information about you, to which you gave your consent when first interacting with such media owner’s services (for example social media platforms).

(ii) Authorized Disclosures. We may disclose your Personal Data to third parties when you consent to a particular disclosure. Please note that once we share your information with a third party, that information becomes subject to the third party’s privacy practices.

(iii) Compelled Disclosures. We will share your information, solely to the extent needed to comply with any applicable law or permitted by it, regulation, legal process or governmental request (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required in order to enforce our policies (including our policies and agreements) including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues. In addition, we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.

(iv) Service Providers. We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf. For example, we use third party cloud and storage services to store and retain your data. Thus, we share your data with third party entities, for the purpose of storing such information on our behalf, or for other processing needs. Such entities include Amazon Web Services (which privacy policy is available at: https://aws.amazon.com/privacy). These entities are prohibited from using your personal information for any purposes other than providing us with requested services

(v) Business Transfers. We may share Personal Data, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.

(vi) We may share aggregate or Non-Personal Data with our affiliated companies and additional third parties in accordance with the terms of this Policy. We may store any type of information on our servers or our cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Services, aggregate statistics, marketing and conduct business and marketing analysis, and to enhance your experience.

USER RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Depending on your relationship with Vidazoo (e.g., if you are a visitor of our Site, user of our Platform or a Business Partner), data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction):

· The right to access your Personal Data that we process;

· The right to ensure your Personal Data is accurate, complete and up to date;

· The right to have your Personal Data amended (by correcting, deleting or adding information);

· The right to object to the processing of your Personal Data, to the extent applicable;

· The right to send or “port” your Personal Data;

· The right to file a complaint with a supervisory authority in your jurisdiction;

· The right to withdraw consent, subject to legal or contractual restrictions and reasonable

notice;

· Right to Non-Discrimination; and

· Rights to submit a “Do not sell” request, where applicable.

Please review our Privacy Rights Overview to learn more.

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data, depending on your relationship with us. If you wish to exercise any or all of the above rights, please download our applicable form available at: [downloadable PDF form] and send it to our Data Protection officer at: dpo@vidazoo.com.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority (in the event you are EEA resident). We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

Opt-Out Information

In addition to your rights detailed above, you may:

(i) opt-out of data collection and sharing process made through 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. For more information about cookies and your controls in this regard, please review your browser settings as well as our Cookies Policy.

(ii) opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website- NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website- DAA opt-out page. Or the European Interactive Digital Advertising Alliance (“EDAA”) website Your Online Choices page.

(iii) our Business Partners may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the Business Partner’s privacy policies. Please note, however, that we are not responsible for the privacy practices of our Business Partners, and other third parties.

(iv) For end user interacting with out Platform (i.e., our media player implemented in our Business Partner’s digital assets) - we require our Business Partners, such as websites and applications that implement our Platforms and serve our Services, and advertisers or content providers that serve and display content on our Platforms, to provide users with an easy to access opt out option. You can also opt out from having content displayed to you based on your data (however it can still be based on a web-page data in which the Platform is implemented). If you which to exercise such opt-out right you may click here. Please be notified though that as we cannot identify you as an individual person, such opt out is cookie based. It means that if you clear your cookies, we will not be able to recognize your user as an opted-out user. By clicking the OPT OUT button above, you opt out from receiving Targeted Advertising based on data collected via your browser.

DATA RETENTION

We retain the information we collect solely for as long as required to fulfill the purposes for which it was collected, and as detailed below:

Log Files (including web logos)

Shall be deleted no later than seven (7) days

Identifiers (IP and UDID)

Shall be deleted no later than six (6) months if

needed for fraud detection.

Notwithstanding the above, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with using the event of any complaints, all, in compliance with applicable laws as well as our Business Partners’ data.

SECURITY MEASURES

We work hard to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry such as: encryption using SSL, we minimize amount of data that we store on our servers, restrict access to Personal Data to Vidazoo employees, contractors and agents, etc. as we further explain in our Security Policy. Note that, we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Further, in the event of a data breach, in which we discover your Personal Data is at risk, we will notify you through the Services or, if technically possible, by sending you an email, subject to applicable law requirements.

Please contact us at: privacy@vidazoo.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

DATA TRANSFER

We may store or process your Personal Data in the United States or in other countries. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your Personal Data requires your consent, then your consent to this Policy includes your express consent for such transfer of your data.

CHILDREN’S PRIVACY

Our Services are not directed nor is it intended for use by children under the age of 16 and we do not knowingly process a children's information. We will discard any information that we receive from a user that is considered a "child" immediately upon our discovery that such a user shared information with us. Please contact us at: privacy@vidazoo.com if you have reason to believe that a child has shared any information with us.

DO NOT TRACK DISCLOSURE

The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

CONTACT US

If you have any questions or comments about this Policy, or any concerns with respect to how your privacy any information are handled, please contact us at:

Vidazoo Ltd.

114 Yigal Alon St, Tel-Aviv, Israel 6744320

support@vidazoo.com

DATA PROTECTION OFFICER:

If you have any requests regarding the data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@vidazoo.com

Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.