Last Updated: May 12, 2019
Sayollo Media Ltd. (together with its subsidiaries, affiliates, officers and directors, as applicable – collectively “Company”, “we” or “us”) is a mobile platform to enable un-interrupted native blending of video content within real-time virtual environments (“Platform”) for the purpose of providing our business partners (“Business Partner(s)”) with the ability to incorporate blended video content and advertisements to be presented to users (“user(s)”) who download, use or who are otherwise interacting with the Business Partners’ mobile applications (“App”) (collectively, “Service(s)“).
We have included below information about which data is collected, how we process, use or share your data, but before, we would like to explain the lawful basis on which we do so, all subject to the EU General Data Protection Regulation (“GDPR”) as well as other applicable data privacy regulations:
(i) We process some Online Identifiers (as defined below) based on our Business Partners’ lawful basis (e.g., legitimate interest od consent provided by the user to the Business Partner);
(ii) Where a Business Partner uses our Services, we process its Personal Data in order to perform our contract with the Business Partner;
(iii) We process contact details voluntarily provided by visitors accessing our website or through other means of communications based on the legitimate interest of providing the requested service.
If you have any questions about this Policy or our privacy practices, please do not hesitate to contact us at: email@example.com
We act as a Processor of certain Personal Data, as defined under the GDPR, such as users’ Online Identifiers on behalf of our Business Partners. We are also a Controller of certain Personal Data, such as our Business Partner’s data, or if individuals contact us or access our website.
Types of Data We Collect
We will collect the following types of data:
“Non-Personal Data”: non-identifiable information which may be made available or gathered through your use of our Services or access to our website. To clarify, processing of Non-Personal Data is not identifiable to a specific individual and as such we are not aware of your identity due to such information.
“Personal Data”: individually identifiable information, namely information that identifies an individual or may with reasonable effort identifies an individual.
In the event we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data for as long as it remains combined.
The table below details the data we collect and how we use it:
How We Collect Data
Depending on the nature of your interaction with the Services, we may collect data from you, as follows:
(i) Automatically – we may use the SDK, web beacons and pixels, cookies, and other similar tracking technologies to gather some information automatically.
(ii) Provided by Business Partner – we will collect information provided by our Business Partners in connection with their use of our Services with respect to their products.
(iii) Provided by you voluntarily – we will collect data if and when you choose to provide us with such data, for example through contact us communications, etc.
Whenever required under applicable law, we will obtain consent prior to collection of Personal Data, or obligate our Business Partners to obtain such consent, and always offer the choice to opt-out.
Web Beacons & Cookies
When you interact with the Services, we may use tracking technologies known as web beacons or “pixels” and or similar technologies. Web beacons or pixels are electronic images. A web beacon is a clear picture file used to keep track of your navigation through an online asset (e.g., website). Web beacons are normally used for traffic monitoring and tracking services. We use web beacons to collection certain information such as type of browser and operating system, type of device, Online Identifiers and so forth in order to understand usage and effectiveness of our Services.
We may permit third parties to use other tracking technologies to collect information about your online and application usage activities across our Services and the website, this data may include Personal Data therefore we recommend you review these third party providers' privacy policies:
Please see the “Choices and Controls” paragraph below for additional opt-out information.
Sharing Data with Third Parties
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events, and solely to the extent needed:
If the Company reasonably believes that you have breached its policies, or abused the Services, or performed any act or omission that the Company reasonably believes to be violating any applicable law, rules, or regulations;
If the Company is required, or reasonably believes that it is required by law or law enforcement agencies to share or disclose your information;
In any case of dispute, or legal proceeding of any kind between you and the Company or between you and other users with respect to, or in relation with the Services;
We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf, for example for security, fraud detection, server and data storage providers, etc.;
We may share your information in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of us, our users or any applicable third party;
We may share Online Identifiers, for the purpose of operating and improving our business, providing the Services, as well as to detect fraud, security or technical issues in connection with the Platform or Services.
Notwithstanding the above, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints, all, in compliance with applicable laws.
How we Protect Data
Further, in the event of a security incident, in which we discover your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
Choices and Controls
You may easily opt out of the data collection and sharing process related to our Service.
Options to opt out:
Android – https://support.google.com/ads/answer/2662922 or
You may set your browser to block cookies, or to indicate when a cookie is being set, by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. For your convenience, see more information about your controls in this regard, within the following links:
Business Partners opt-out:
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 privacy policies of their applications to learn more about the privacy practices of our Business Partners. Please note, however, that we are not responsible for the privacy practices of our Business Partners, and other third parties.
You may also contact us at: and we will be happy to assist you.
Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Data that we hold (which might be different in each jurisdiction) such as; right to access your Personal Data; right of rectification; the right to erasure of your Personal Data; right to restrict processing of your Personal Data; the right to object to processing of your Personal Data; data portability; the right to file a complaint to a supervisory authority (in the event you are EEA resident); and, the right to withdraw consent. For more information regarding individuals’ rights under the GDPR, please review our Data Subject Rights Overview: www.sayollo.com/data-subject-rights
If you wish to exercise any or all of the above rights, please fill out the Data Subject Request (“DSR”) form available www.sayollo.com/dsr.pdf and send it to our privacy team at: firstname.lastname@example.org.
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.
Transfer of Data
Do Not Track Disclosure
The Services does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/.
Children’s Privacy and Eligibility
Comments and Questions
Sayollo Media Ltd.
2 Oppenheimer St., Rehovot, Israel.
Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.