Last updated: September 17, 2022
Table of Contents
- Data Collection, Sources & Use
We collect data regarding our Visitors, Publishers and Advertisers. Such data is typically collected and generated through your interaction with our Sites, through automatic means, directly from you, or from other third parties. Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “personal data“):
- Prospect contact details – such as name, telephone number, email address, location (country, city), your position and other information that might be relevant for our further growth and business relationship. We collect such details to communicate with you, provide you with the Services, products or demonstrations that you might request, customize the Services for you, improve and enhance our Services, market our Services to you and facilitate, sponsor, and offer certain events and promotions;
- Account information for your business account – such as username, password, product interaction, feedback and any other information you choose to include in communications with us or arising from your use of the Services. 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, administer the relationship between our companies, improve and enhance our Services, and conduct research and analytics.
- Data automatically collected and generated – such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, data regarding the device, operating system, browser version, and locale settings used when interacting with the Sites, the cookies and pixels installed on such device and your activity (clicks and other interactions) in connection with our Services.
- Data received from our Publishers and Advertisers – such data consists of name, role, company and work or personal contact details, as relevant, however additional data may be provided at the Publisher’s or Advertiser’s discretion. Our Publishers and Advertisers may provide us with this data concerning their colleagues or employees so we could contact them to offer or provide them with our Services.
- Data received from other third parties: we may receive your personal data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your personal data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or services providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn, data enrichment and other networking or sourcing services.
In addition, we use personal data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, advertising, customer service and support operations, and protecting and securing you, ourselves and our Services, as well as members of the general public.
Further, we use personal data for the following purposes:
- To facilitate, operate, and provide our Services;
- To authenticate your identity, and to allow you access to our Services;
- To provide you with assistance and support;
- To further develop, customize and improve the Services and your experience, based on common or personal preferences, experiences and difficulties;
- To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services.
- To contact you with general or personalized service-related messages and calls, and promotional messages and calls (as further described in Section 6 below); and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security and content compliance measures, including for the purposes of preventing and mitigating the risks of fraud, abuse, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
- Data Sharing
In certain instances, we may share your personal data with third parties, as described below:
- Third-party service providers: companies that perform services on our behalf and complementary to our own (e.g. data hosting, analytics, advertising and marketing, data and cyber security, payment processors, user engagement services, e-mail distribution and monitoring services, text messaging services, and our business, legal and financial advisors) (collectively, “Service Providers“);
- With our affiliates or otherwise 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, you, our Publishers, Advertisers, personnel and users.
For the avoidance of doubt, we may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.
- Data Location & Retention
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 keep your personal data for as long as reasonably necessary in order to maintain and expand our relationship and to provide you with our Services.
We will also retain your personal data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our internal data retention policy.
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.
Our Services utilize “cookies,” anonymous identifiers, pixels and other technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.
A list of the cookies we use, information concerning our advertising partners, 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
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/.
Service Communications: 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.
Notifications and Promotional Communications: We may also send you notifications, messages and other updates about new features, offerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us, through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify us 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 promotional communications you receive, or by sending an email to firstname.lastname@example.org.
- Data Security
We use 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 data, including 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.
- 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 3) and deletion (Section 8) practices in the preceding 12 months. We also included information about how we may process your information (in Sections 1 through 6), 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.
- Contact Us
Data Protection Officer: OpenWeb has appointed a Data Protection Officer for monitoring and advising on our ongoing privacy compliance, as well as serving as a point of contact on privacy matters for data subjects and supervisory authorities. Our DPO may be reached by email at email@example.com, or by mail at: OpenWeb Ltd. (Attn: DPO), Yigal Alon 94, Tel Aviv 6789156, Israel.