[Last Modified: January 20, 2019]
Cedato Technologies LTD (collectively with its affiliates and subsidiaries shall be referred to as “Cedato”, “we,” “us,” or “our”) is an online advertising and technology company that provides a video operating system (“Player”), and an ad serving platform offering real-time bidding (“RTB”) tool (“Marketplace”) (collectively with the Player and Marketplace, shall be defined herein as “Services”). We enable demand and supply partners (“Business Partners”) to use our Services for optimizing and enhancing their video campaigns.
Further, our Player enables end users to enjoy an enhanced viewing experience of video content, including advertisement, over mobile web pages, desktop websites and connected TV (“Digital Assets”). Further, in some case, through the Marketplace, we place our own demand, ads, and content on the aforesaid Digital Assets.
In order to provide the Services, we collect and use certain information about our Business Partners, the end user as well as individuals browsing and visiting our Website (all, shall collectively be defined herein as “you” or “your” unless specifically stated otherwise).
We have included below information about which information is collected, how we process and use your data, but before we would like to explain the lawful basis on which we do so:
- Where you sign up for any of our Services, we process your Personal Data in order to perform our contract with you;
- If we have a legitimate interest in processing data, such as for direct marketing or online identifiers when you access our Website or interact with our Services; or
- We will also process your Personal Data where you have provided us with consent to do so.
- Where the Company acts as a demand partner on the Marketplace, hence, serving ads to the end user through the Player and Digital Assets, we will process end users’ IP, Adverting IDs, cookies, etc. (“Online Identifiers”) together with other data, such as your preference, searches, and insights (“Profiling Data”) will be processed based on the lawful basis of consent.
If you have any questions about this Policy, please contact us at firstname.lastname@example.org (or as described below).
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 Website. 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. Your continued use of the Services following the display of such modified Policy constitutes your acknowledgment and consent of such amendments and your agreement to be bound by the updated terms. We recommend you to review this Policy periodically to ensure that you understand our most updated privacy practices.
Information We Collect
Our Player, used in the Digital Assets, is a software that allows our Business Partners to provide users with video content, including personalized content and advertisements. We may track this information over time and across multiple devices (and may also combine it with additional data from other sources) in order to deliver targeted advertisements through the Player. In addition, we may collect information during your interaction with our Services or Website, as applicable. We may collect information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”) or non-identifiable information which may be made available or gathered via your use of Services or the Website (“Non-Personal Data”), the types and methods of gathering are specified in the table below:
|Type of Information||How Do We Use the Information and the Purpose of Collection|
|Contact Details Email Address
If you contact us in any manner, including through the “Contact Us” page in the Website, support, request to “schedule a meeting” form, request for “more information” form, or any other request or notification, whether by submitting an online form that we make available or by sending an email to an email address that we display, or in any other manner, you may be required to provide us with certain information such as your name and email address.
|We collect this information in order to perform our contract with you, meaning, in the event you contact us through the Website, or through any other means of communication, we will use your contact details and 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. We will send you a “Welcome” email and following our applicable team representative will contact you.
In addition, we may, under our legitimate interest, inform our Business Partners about our services, such as upcoming changes or improvements, events, etc.
|Newsletter, Informative Marketing Subscription
If you voluntarily subscribe to our Newsletter you will be asked to provide us with your name and email address. You can unsubscribe at any moment through the “unsubscribe” link. Note that, requesting to unsubscribe from marketing messages will not stop service communications (such as order updates or where you have expressed an interest in activity at our Website). If you voluntarily submit an online in order to receive an ePaper from us or view our webinar, you will be asked to provide us with your name and email address.
|If you voluntarily register to our newsletter and events updates or otherwise submit a form requesting to receive any materials from us (e.g., ePaper, information regarding our Services, etc.), we will use your information to provide you with the materials you have requested.|
|Online Identifiers and Technical Non-Personal Data We may collect certain Online Identifiers such as your IP addresses, Android ID, Advertising ID (if you are using an Android device) and IDFA (if you are using an iOS device). Further, we may collect technical Non-Personal Data which may be made available or gathered via your use of Services or the Website. This information includes your aggregated usage information and technical information transmitted by your device, as type of operating system, type of browser, the time and date you access the Services or the Website, connect or disconnect to the Services, user’s actions (i.e., regarding its view and interaction with the Services and the Website), approximate geographical location, log files, when you use our Services or interact with the Player, we may collect and store certain information in server logs, redirecting URLs.||We use Online Identifiers in order to customize your experience and provide users of the Digital Assets with personalized content and ads and for optimization, performance and analytic purposes.
The Online Identifiers might be collected by us or by our third-party partners which their Cookies we use in our Website, or in the Marketplace as detailed below.
Further, we may employ third-party on our Website for remarketing purposes.
We will use the technical data as well as for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Website and Services and the way in which we offer them; (ii) enhancing your experience with the Website and Services; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow, detecting fraud, security or technical issues in connection with the Website and Service, auditing our affiliates, and calculating payments; (iv) perform research, for analytical and statistical purposes; and (v) to optimize the content served through the Player based on the user’s preferences, uses and interactions with the Services.
|Registration, Account & Help Center
|We will use this information for the purpose of performing our contract with you, 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 and phone number in order to send you needed information related to the Services and our business engagement (e.g., send you a Welcome message, to notify you regarding any updated to our Services, send applicable invoices, and additional occasional communications related to the Services) as well as verify your identity. In the event you provide us with your Twitter account, your information will be used to link your comments to your Twitter profile. In the event you upload UGC to the Website or Services, such data, including any Personal Data shall be subject to your own use.|
If you are interested in working with us, you may voluntarily send us your CV through the applicable button located in the Website.
|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 the 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.|
Combination of Personal & Non-Personal Data
If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data for as long as it remains combined.
How We Collect Information
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 JS code, Cookies (as detailed below), and other similar tracking technologies when you interact with our Player or visit our Website; or (ii) when you voluntarily choose to provide us with information, i.e. when you contact us, register to our Newsletter, etc., all as detailed in this Policy. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide us or that we collect automatically. 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
For more information about cookies and your controls in this regard, you may review the following links:
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 block or erase cookies some features of the Services may not operate properly and your online experience may be limited
|Facebook Analytics||Enable use of the Service||https://www.facebook.com/policies/cookies/|
|Google AdWords||Marketing and Remarketing||https://policies.google.com/privacy|
|Google Analytics||Analytic purposes||www.google.com/policies/privacy/partners|
|Marketing and Remarketing||https://twitter.com/en/privacy|
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) 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.
(ii) 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.
(iii) Agents / Service Providers. We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf (among others, as detailed in the “Cookies and other technologies” Section above). For example, we may share your email address with a third-party service provider in order to assist us with email marketing. These entities are prohibited from using your personal information for any purposes other than providing us with requested services.
(v) Identifiers. We may share Online Identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the Services.
Regarding Non-Personal Data, we may share or aggregate Non-Personal Data with Business Partners and other third parties in accordance with the terms of this Policy. We may store Non-Personal Data and Personal Data 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 Service as detailed above. Furthermore, we reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
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 Cedato (e.g., if you are a user or Business Partner), data protection and privacy laws provide you with the following rights regarding your Personal Data:
- the right to access your Personal Data that we hold;
- the right to request the rectification of your Personal Data that we hold;
- the right to request the erasure of your Personal Data that we hold;
- the right to request to restrict processing of your Personal Data;
- the right to object to the processing of your Personal Data by us;
- the right to request to transfer your Personal Data that we hold (e., data portability);
- the right to file a complaint to a supervisory authority in your jurisdiction; and
- the right to withdraw consent.
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 and fill in our user right request form available at www.cedato.com/user-form. and send it to our Data Protection Officer at email@example.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. 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. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
You may easily opt out of the data collection, sharing the process and targeted advertising services related to our Service. Please note that even if you opt-out, you may still receive content and advertising, however, it will not be targeted:
- You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set by us, by adjusting the privacy and security settings of your web browser. Please refer to Cookie section above for more information.
- You may limit the disclosure of certain Personal Data, specifically Online Identifiers, through your mobile device by adjusting the settings. Please read your device specific information to learn how to opt-out:
- You may 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.
- 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.
If you would like additional information about your choices and controls related to your information, or you would like to access your Personal Data, please contact us at firstname.lastname@example.org or contact our Data Protection Officer at email@example.com.
Data Retention Policy
We retain the Non-Personal Data we collected for as long as needed to provide the Service, carry out our business purpose and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed above under the “User Rights” section, for more information please see out data retention table:
|Online Identifiers (including applicable log files)||Shall be deleted every seven (7) days|
|Raw Data||Shall be deleted immediately and no later than 24 months|
|Partner Data (i.e., name, banking details)||Unless requested by the partner, this data can be kept for seven (7) years due to tax law.|
We work hard to protect Cedato and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of your Personal Data we hold. 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 the amount of data that we store on our servers, restrict access to Personal Data to Cedato employees, contractors, and agents, etc. However, we can’t provide 100% security and 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 be able to prevent such access. For more information regarding Cedato’s Security Measures, please click here .
If you have a reasonable concern with that any person attempted to abuse our Service or gain unauthorized access please contact us at firstname.lastname@example.org. 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.
If you become aware or have any reason to believe that a Child has shared any information with us, please contact us at email@example.com.
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/.
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:
Cedato Technologies LTD.
6A Hanagar St. Hod Hasharon, Israel. ZIP 4527704.
You can also contact us via email at firstname.lastname@example.org
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:
Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.