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We, OpenWeb Technologies Ltd. (together with its affiliates companies – “OpenWeb”, “we”, “our” or “us”) have created our commenting and social engagement platform (“Platform”), applications, services, tools and features (collectively, the “Services”) to help online website publishers (“Publisher(s)”) create a healthier, less toxic environment for their readers, keep their audience engaged within their assets, and create an additional revenue stream by serving advertisements (“Ads“) on behalf of third-party companies (“Advertiser(s)“) through the Publishers’ online assets (“Publisher Site(s)“).
- Data Collection, Sources, & Use
In order to provide you with the Services, you may be required to provide us with certain personal data. Such data is typically collected and generated through your interaction with our Services, or received from third parties, such as our Publishers, in order to enable your use of our Services while on the Publisher Site (e.g., leaving comments in a Publisher Site via our Platform).
Specifically, we collect the following categories of personal data:
- Basic signup information, such as name, email, username, password and profile picture.
- How & what? This information is provided to us directly by you when you sign up for our Platform (either directly from you, or by connecting any of your personal accounts (e.g. with Facebook, Google or Microsoft), or by the Publisher with whom you already have an existing account.
- Why? We collect this information to provide you with the Services, authenticate your identity, secure your account with us, personalize the Services for you, communicate with you, improve and enhance our Services, and conduct research and analytics.
- Account activity, interactions & feedback, including your comments, likes, preferences, and other interactions within our Platform.
- How & what? When you engage and interact with our Platform, we collect all related data – such as your comments, likes, configured preferences, and interactions, including with other users on our Platform.
- Why? We collect this information to provide you with the Services, personalize the Services based on your preferences and interactions, improve and expand our Services, and conduct research and analytics.
- Data automatically collected and generated, which typically consists of connectivity, technical and aggregated usage data.
- Why? We collect and process Usage Data to provide you with our Services, to personalize and improve them, to conduct research and analytics, to advertise to you, including contextual, cross-channel, interest based and other types of targeted advertising, and to monitor the performance of our advertising campaigns.
- Data received from third parties, in order to improve our offering to Advertisers, we may contract third party data providers.
- How & What? We may supplement Usage Data with data obtained from third parties, this may include inferred demographic information, including presumed age, gender, income level and general location (state/city based on IP address).
- Why? We use such data to advertise to you, including contextual, cross-channel, interest based and other types of targeted advertising, and monitor the performance of our advertising campaigns.
- Data Sharing
In certain circumstances, OpenWeb may share your personal data with third parties, as described below:
- Third-party service providers: companies that perform services on our behalf, such as hosting, storage, analytics, advertising and marketing, database management, user engagement, cyber and data security, e-mail distribution and monitoring services, text messaging services, and our business, legal and financial advisors (“Service Providers”).
- Publishers: Publisher(s) operating the Publisher Site where you engaged with our Services. We may share your basic signup information, your account activities, interaction and feedback, Usage data and data obtained from third parties to provide our Services
- Advertisers: Advertisers on whose behalf we are serving Ads for. We share Usage Data and data obtained from third parties to provide our advertising offering.
- Within our corporate group.
- To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
- In connection with an asset sale, merger, bankruptcy, or other business transaction.
- To ensure the rights, interests, safety, health and security of OpenWeb, our Publishers, Advertisers, personnel and others.
- Data Location
We and our authorized Service Providers maintain, store and process personal data in the United States, the European Union, Israel and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
- Data Retention
We may also retain and use personal data about you to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. If you stop using our Services, we may store your data in an aggregated and anonymized format, in which case, we may use this data for a longer period without further notice to you.
Please note that except as required by applicable law, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at email@example.com.
A list of the cookies we use, information concerning our Advertisers, their policies as well as additional information about cookies, including our support of transparency and control initiatives (such as NAI & EDAA), can be found HERE.
Please note that in some cases, opting out of cookies, removing cookies, or completely blocking them, will not prevent you from seeing Ads sourced from us, but it will affect the types of Ads that you will see. These Ads will no longer be tailored to your interests and instead will be chosen based on the particular website that you are viewing (i.e. contextually based Ads).
Do-Not-Track (DNT) signals: Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our Services are not specifically designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/
- Advertising Uses
Our Services utilize advertising for third party services and products. We and our Advertisers use certain data about you in order to improve our advertising practices and make the Ads we deliver more relevant, enjoyable and effective, including by deploying contextual, interest-based and other types of advertising, as well as targeting, ad measurement and attribution systems. The Ads and content we or our Advertisers deliver may be shown within our Services or through other channels, such as third-party websites and applications.
Such data includes your IP address, cookies, pixels and other unique identifiers, and other demographic and interests-based information that we or our Advertisers may have received from or about you, based on your consent or another legal basis (i.e., as required in order to provide you with our respective services, or based on the legitimate interests that we described above).
Additionally, we may share data that we collect from you with our identity partners/service providers. Such partners return an online identification code that may then be stored in a first-party cookie for our use in online and cross-channel advertising, and may also be shared with advertising companies to enable interest-based and targeted advertising. The information shared for such activities may include a hashed and non-identifying representation of your email address, your IP address, and technical information about your browser and operating system. To opt out of this use, please click HERE
We may contact you with important information regarding our Services. For example, we may notify you, through any of the means available to us, of changes or updates to our Services, password reset requests, etc. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
We may also send you notifications which relate to your interaction with the Service (likes, comments, etc.). If you do not wish to receive such communications, you may notify OpenWeb at any time by changing your communications preferences in your account, by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the communications you receive, or by sending an email to firstname.lastname@example.org.
- Data Security
We are using industry-standard physical, procedural and electronic security measures to protect your personal data held with us, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any other third party.
- Data Subject Rights
If you wish to exercise your privacy rights under applicable law, including the GDPR, UK GPDR or the CCPA, please follow the instructions available on our dedicated GDPR & CCPA Notices or contact us by email at email@example.com.
Please note that once you contact us by e-mail, we may require additional information and documents, including certain personal data, in order to authenticate and validate your or your authorized agent’s identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 4 above.
- User Generated Content
Our Services allows individuals to comment and upload content to the Services, which others may engage and interact with. Such content may include messages, photos, etc. (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Given the nature of our Services, others who have access to UGC may have the ability to share it with third parties. If you choose to submit UGC to the Services, your UGC will be considered “public” and will be accessible by anyone.
Please note that we do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on our Services or the Publisher Site, or what others do with information you share with them on such platforms. We are not responsible for the accuracy, use or misuse of any UGC that you disclose or receive from third parties through the forums or email lists.
- Additional Notices
California Requirements: This policy describes the categories of personal information we collect and the sources of such information (in Section 1 above), and our retention (Section 4) and deletion (Section 9) practices in the preceding 12 months. We also included information about how we processed your information in the preceding 12 months(in Sections 1 through 7), which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. For additional information regarding how we handle information of California residents, please review our CCPA Notice.
Children’s Privacy: Our Services are not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at firstname.lastname@example.org.
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