Last Updated: 07/11/2015
Your California Privacy Rights
If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please email us at: email@example.com; or telephone us at: +972 3642 6937.
Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please email us at: firstname.lastname@example.org; or telephone us at: +972 3642 6937. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.
Information Collected on the Site
Collecting Non-Personally Identifiable Information We automatically collect Non-Personally Identifiable Information when you access and use the Site. This Non-Personally Identifiable Information includes, without limitation, the type of browser that you use (e.g., Internet Explorer, Chrome, Safari), your IP address, the type of operating system that you use (e.g., Windows or Mac OS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the Non-Personally Identifiable Information to help diagnose problems with our server, to personalize your Internet experience and to identify ways of making the Site better. We also may use this Non-Personally Identifiable Information in the aggregate to analyze Site usage, as well as to offer you products and services. This Non-Personally Identifiable Information is not linked to any Personally Identifiable Information.
Identifying, Deleting, Modifying and/or Updating Your Information At your request, we will inform you of what Personally Identifiable Information we have on file for you. If your Personally Identifiable Information changes, if you no longer wish to participate in the Hooly Network, if you no longer wish to participate in our Promotions or if you no longer desire to access our other products and/or services, you may correct, update, amend or delete your Personally Identifiable Information by making the changes on your account page, by emailing our customer support department at: email@example.com or by contacting us by +972 3642 6937 or postal mail using the contact information listed below; provided, however, that we ask individuals to identify themselves and the Personally Identifiable Information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Opt-Out/Unsubscribe to opt-out of having your Personally Identifiable Information shared with third parties, please email us at:firstname.lastname@example.org. To opt-out of receiving e-mail marketing, telemarketing and direct mail marketing from us, you can follow the instructions at the end of the applicable marketing message or email us at:email@example.com.
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for participation in the Hooly Network, your participation in Promotions, as well as to respond to any inquiry or request made by you. To opt-out of receiving Hooly Network-related, Promotions-related and/or inquiry response-related messages from us, you must cease requesting and/or utilizing the Hooly Network, cease participating in the Promotions and/or cease submitting inquiries to us, as applicable.
Cookies, Tracking Technologies and Setting of Digital Identifiers Most Internet browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. To disable and reject certain cookies, follow the instructions associated with your Internet browser. Even in the case where a user rejects a cookie, he or she may still use the Site.
We automatically use Digital Identifiers (as defined below) for tracking transactions, identification, security and the user characteristics as set forth herein. No Personally Identifiable Information is collected by use of digital identifiers and we use the information collected through such Digital Identifiers, which may also include information about the precise geographic location of the device, which may be collected when the user of the device permits such collection, to analyze trends, administer the Site, track movements on the Site and gather aggregate demographic information, about visitors so we can continually improve the Site, our performance network, in order to buy and sell online advertising, including interest-based advertising, using Real-Time Bidding and our other products and services.
Real-Time Bidding: Are complex technological tools or platforms that enable advertising buyers to bid in “real time” for the opportunity to show an online advertisement when a web page is loaded or an app is used.
We also employ, and our third-party advertising partners employ, Digital Identifiers that help us better manage content and/or track transactions, collect data, serve advertising and provide related services. Unless expressly indicated otherwise, we do not tie the information gathered by Digital Identifiers to our customers’ Personally Identifiable Information.
Beacons, Pixels and Tags: Beacons (also sometimes referred to as web beacons or pixels) and tags enable online advertising companies to collect data, serve advertising, and provide related services, such as measurement or fraud prevention, on websites by allowing communication between a web browser and a server. A beacon is a small transparent image that is placed on a web page. A tag is a small piece of computer code that is run by the web browser.
Mobile SDK: A mobile SDK is the mobile app version of a beacon or tag (see Beacons and Tags above). The SDK is a piece of computer code that publishers include in their apps to enable ads to be shown and to enable related services, such as measurement or fraud prevention, including by collecting and analyzing data which is available through the device on which the mobile SDK is installed.
Cookie: A cookie is a small text file that is stored in a web browser by a website or ad server. By saving information in a cookie, websites and servers can remember preferences or recognize browsers from one visit to another or from one website to another.
Non-Cookie Technology: Today’s online world is becoming increasingly complex, with a proliferation of new devices, software platforms, online services and other technology. As such, cookies are not always available. Therefore, companies are using alternative methods to distinguish devices. For example, some platforms, such as Apple’s iOS and Google’s Play Services for Android, provide unique IDs to be used for advertising. Most mobile devices are assigned unique identifiers that also may be used to distinguish devices. Additionally, it is possible to use mathematical techniques to make intelligent guesses about recognizing devices.
We also gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the Site, to track users’ movements around the Site and to gather demographic information about our user base as a whole.
We do not link this automatically-collected data to Personally Identifiable Information.
Without deviating from the terms set forth above, including with respect to potential use of Non-Cookie Technology, the Hooly Network uses the following: (a) unique cookies to identify web browsers and to store data for advertising purposes, including interest-based advertising; (b) unique cookies to track users’ responses (clicks and conversions) to ads purchased; (c) non-unique cookies to store users’ opt-out choices.
Please note the digital identifiers on the Site may change periodically and we will update this preference manager accordingly to have the most up to date digital identifiers included in this tool.
The Site may also include links to third-party social media websites such as Facebook®, Twitter®, LinkedIn® and Google+®, as well as associated social media features and scripts, such as the Facebook® “like” button and widgets. These features and scripts may collect your IP address, which page you are visiting on the Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by the applicable third party social media website or hosted directly on the Site. Your interactions with these social media features and widgets, as well as your interactions with the social media websites themselves, are governed by the privacy policies of the applicable social media websites.
If you submit Personally Identifiable Information in a comment on a blog post and/or on any applicable social media websites, you should be aware that the Personally Identifiable Information that you submit using such forums can be read, collected or used by other users of these forums (depending on your privacy settings, in the case of social media websites), and could be used to send you unsolicited messages or otherwise contact you without your consent or desire. We are not responsible for the Personally Identifiable Information that you choose to submit in these forums.
We display personal testimonials of satisfied customers on the Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at: firstname.lastname@example.org.
We may also cooperate with other companies and individuals to perform certain functions on their behalf. Examples include sending direct and electronic mail, analyzing data and providing marketing analysis. Where we perform these functions on behalf of third parties, we may be granted access access to certain users’ Personally Identifiable Information as needed to perform these functions in which event the provision thereof shall be governed by the applicable policies of those third-parties.
Information Collected by and Through the Hooly Network and how it is Stored
Non-Personally Identifiable Information Collected During your access and use of the third-party desktop and mobile websites of our partners in the Hooly Network, we automatically collect Non-Personally Identifiable Information such as IP addresses, browser and device type, device identifiers, as well as how you interact with these third party website(s), through the use of Digital identifiers. This information may be collected directly by us or with the help of a partner. We use this information to help us and our partners understand how you interact with these websites and to display advertisements that may be relevant to your interests. We may also receive additional Non-Personally Identifiable Information from third-party sources. The information we receive is not linked to any Personally Identifiable Information.
We will retain the information we receive about you through the Hooly Network indefinitely.
Information Use and Sharing By submitting your Personally Identifiable Information by and through the Site or otherwise in connection with your participation in the Hooly Network or a Promotion, you agree that we may share, sell, rent, lease or otherwise provide that Personally Identifiable Information (other than credit card, bank account or other payment information) to any third party for any purpose permitted by law, and we may work with other businesses to bring selected retail opportunities to you. These businesses and third parties may include, but are not limited to: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) email marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. We will also use your Personally Identifiable Information to send you promotional messages regarding various Hooly products and/or services, as well as third-party products and/or services, that we think may be of interest to you.
Hooly may provide, or enable others to collect, information for purposes of detecting and preventing malicious activity or invalid traffic, or pursuant to any legal requirement or governmental requirement. Hooly may also share aggregate data derived through the Hooly Network, including, for example, statistics about Hooly Network activity. We may transfer Hooly Network data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
We may also employ with other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from member lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our users’ Personally Identifiable Information as needed to perform these functions for us, but we do not permit them to use Personally Identifiable Information for other purposes.
We will also use your Personally Identifiable Information for customer service, to provide you with information that you may request, to customize your experience with the Site, the Hooly Network, Promotions and/or to contact you when necessary in connection with same. We may also use your Personally Identifiable Information for internal business purposes, such as analyzing and managing our business including, without limitation, the Site and the Hooly Network. We may also combine the Personally Identifiable Information we have gathered about you with information from other sources.
By submitting your Personally Identifiable Information by and through the Site or otherwise in connection with your participation in the Hooly Network or a Promotion, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.
We may also disclose your Personally Identifiable Information: as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a government request; if we are involved in a merger, acquisition, sale of all or a portion of our assets or are the subject of bankruptcy proceedings, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personally Identifiable Information, as well as any choices you may have regarding your Personally Identifiable Information; and in the event that we believe that the Site and/or Hooly Network is/are being or have been used in violation of the applicable Hooly agreements or to commit unlawful acts.
We may use third-party service providers to enhance our database with additional elements of our services.
Aggregated data is used for reporting and analysis, and may be stored in the Site and/or Hooly Network for as long as there is a business need to maintain such data.
Security We endeavor to safeguard and protect our users’ Personally Identifiable Information and use generally accepted industry security standards in order to secure such information. When users make Personally Identifiable Information available to us, their Personally Identifiable Information is protected both online and offline (to the extent that we maintain any Personally Identifiable Information offline). Where our registration/application process prompts users to enter sensitive information (such as credit card or bank account information), and when we store and transmit such sensitive information, that information is encrypted and is protected with SSL encryption software.
Access to your Personally Identifiable Information is strictly limited, and we take reasonable measures to ensure that your Personally Identifiable Information is not accessible to the public. All of our users’ Personally Identifiable Information is restricted in our offices. Only employees or third party agents who need the Personally Identifiable Information to perform a specific job are granted access to Personally Identifiable Information. Our employees are dedicated to ensuring the security and privacy of all user Personally Identifiable Information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store Personally Identifiable Information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of Personally Identifiable Information under our control.
Please be advised, however, that while we take every reasonable precaution available to protect your Personally Identifiable Information, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your Personally Identifiable Information, and technological bugs, errors and glitches may cause inadvertent disclosures of your Personally Identifiable Information; provided, however, that any attempt to breach the security of the Hooly Network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your Personally Identifiable Information will be absolutely secure. Any transmission of data at or through the Site or otherwise via the Internet or wireless network is at your own risk.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personally Identifiable Information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
Minors We do not knowingly collect information from individuals under eighteen (18) years of age. No information should be submitted to, or posted at, the Site by individuals under eighteen (18) years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
Hooly Ltd. 15 Alharizi St. Tel Aviv 64244 Israel