Cedato Privacy Policy

[Last Modified: March 3, 2020]

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.

Your privacy is of high importance to Cedato, and we want you to fully understand how we are collecting and using information during your use of the Services, Digital Assets, or our website available at: https://www.cedato.com/ (“Website”) as well as the ways in which you may exercise your rights. Thus, we strongly recommended you to take the time to review this Privacy Policy (“Policy”) and understand our privacy practices.

Further, our Player enables end users to enjoy an enhanced viewing experience of video content, including advertisement, over mobile webpages, 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).  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, as required under the GDPR: (1) when our Business Partners register to our Services, we process their Personal Data in order to perform our contract with them; (2) when you access our Website or Services we may collect certain Online Identifiers (as defined below) 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.
    • 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”) this will be processed based on the lawful basis of consent (provided by the owner of the Digital Assets)
    • 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: privacy-inquiries@cedato.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 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. 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. 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 Purpose of Collection Lawful Basis under the GDPR
Contact Details

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, interact with the online chat available in the Website 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 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.

 

We use HubSpot chat services. Hubspot privacy policy can be found here: https://legal.hubspot.com/privacy-policy

Performance of a contract.

Necessity of processing for the purposes of our legitimate interests

Newsletter, Informative & Marketing Subscription

If you voluntarily subscribe to our Newsletter you will be asked to provide us with your name, email address and company name. 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 an 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.

 

Your consent.

 

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.

Performance of a contract.

Our legitimate interests.

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

Registration, Account & Help Center

If you voluntarily choose to access and use our support provided through our help center, you will be required to provide us with your name, email address and in some events your phone number. In addition, if you wish, you may provide your Twitter account. Other than that, if you voluntarily choose to provide Personal Data through any posts, questions, etc., you submit in the forum included in our help center (i.e., user generated content (“UGC“)), provide Personal Data, we may collect such UGC.  Our help center is offered through Zendesk that will have access to collect and proses the above Personal Data solely for the purpose of facilitating communication with you and record-keeping. For more information, please see Zendesk privacy policy.

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 massage, 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. Performance of a contract.

 

Recruitment

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 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. Your consent.

 

Please note the following:

    • We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Website and Services, as detailed above.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.
    • We act as a Controller of the Personal Data collected from our Business Partners and Website’s visitors. In addition, we act as a Processor of certain Online Identifiers collected on behalf of our Business Partners in order to provide the Services

How We Collect Information

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

    • 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;
    • 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.

Cookies and Similar Technologies

When you access or use the Website, or interact with our Services or the Player, 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 assigns and stores on your device while you are viewing a website. The cookies used by the Website do not include any Personal Data about you. 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. You can find more information about cookies at: www.allaboutcookies.org and https://cookiepedia.co.uk/

There are several types of cookies, the three main and common ones are:

    • Essential, Functionality, Operation & Security Cookies – essential for enabling user movement around the website, for the website to function properly, and for security purposes. Please note that these cookies either cannot be disabled, or if disabled, certain features of the Services may not work.
    • Analytic, Measurement & Performance Cookies – used to collect information about how users use the Website (clickstream, navigation, time and date of access, etc.) in order to improve our Services and the way we offer them, as well as assessing performance of the content available in the website. We further use this information to compile reports and calculate payments in the course of relationship with our Business Partners.
    • Preference, Targeting & Advertising Cookies – used to advertise across the internet and to display relevant ads tailored to users based on the parts of the website they have (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage).

We may permit third parties to use cookies or other technology to collect information about your online and application usage activities across our Website as follows:

Cookie Purpose Privacy Policy and Opt-Out
CloudFare Enable use of the Service https://www.cloudflare.com/privacypolicy/
Facebook Analytics Enable use of the Service https://www.facebook.com/policies/cookies/
Google AdWords Marketing and Remarketing https://policies.google.com/privacy

https://adssettings.google.com/authenticated

Google Analytics Analytic purposes www.google.com/policies/privacy/partners

 https://tools.google.com/dlpage/gaoptout

Google doubleclick Marketing and Remarketing https://policies.google.com/privacy?hl=en
HubSpot Direct Marketing https://legal.hubspot.com/privacy-policy.
LinkedIn Marketing https://www.linkedin.com/legal/privacy-policy

https://www.linkedin.com/legal/cookie-policy.

Twitter Marketing and Remarketing https://twitter.com/en/privacy

https://help.twitter.com/en/rules-and-policies/twitter-cookies

For additional information of our use of Google products, click here.

    • Cookies Opt-Out. 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. By following the instructions of your device preferences, and by adjusting the privacy and security settings of your web browser, you may remove cookies and easily opt out of the data collection, sharing process and targeted advertising services related to our Service. For more information about cookies and your controls in this regard, you may review the following links:
    • 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:

Android – https://support.google.com/ads/answer/2662922

iOS – https://support.apple.com/en-il/HT205223.

    • 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.
    • Please note that even if you opt-out, you may still receive content and advertising, however it will not be targeted.
    • 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: privacy-inquiries@cedato.com or contact our Data Protection Officer at: dpo@cedato.com.

Direct Marketing

We may send our Business Partners an email or other messages about us or our Services. We may also send our updates or newsletter to individuals who have registered to these Services. You can remove your Personal Data from our mailing list and stop receiving promotional communications from us by following the unsubscribe link located at the bottom of each communication or by emailing us.

Please note that in the event you are our Business Partner, even if you unsubscribe, we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions the Services, without offering you the opportunity to opt out of receiving them unless you terminate and delete your account. If you wish to delete your account, please contact us at the email above. Note that even if we will delete your account, we will not delete certain information required under applicable law or otherwise, required for the legitimate purposes of our business. For example, we will not delete any invoices sent to you as we need it for the purpose of managing our financials.

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.

(iv) 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 Privacy Policy.

(v) Online Identifiers. We may share Online Identifiers or Cookies ID 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.

User Rights

Data protection and privacy laws may provide you with some of the principal rights (depending on your jurisdiction) with respect to your Personal Data, for example:

    • The right to access your Personal Data;
    • 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;
    • The right to send or “port” your Personal Data;
    • The right to file a complaint with a supervisory authority in your jurisdiction; and

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

Please review our Privacy Rights Overview to learn more.

In the event that you contact us and request to exercise any of your rights detailed above, we may request that you provide us with certain information in order to verify your identity and locate your data. Such process may take certain period, subject to applicable privacy laws (for example one month under the GDPR).

Please note that, you may have different rights than those which we listed above subject to privacy protections laws in your jurisdiction.

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.

Security Measures

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 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 reasonable concern with that any person attempted to abuse our Service, or gain unauthorized access please contact us at: privacy-inquiries@cedato.com. 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.

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 Privacy Policy includes your express consent for such transfer of your data.

Children’s Privacy

Our Website and Services are not directed nor is it intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law and specifically under the age of 16) and we do not knowingly process a child’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-inquiries@cedato.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:

Cedato Technologies LTD.
6 Hanagar St. Hod Hasharon, Israel. ZIP 4527704.
You can also contact us via email at: privacy-inquiries@cedato.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@cedato.com

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