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PRIVACY POLICY

PRIVACY POLICY

 Last Updated: March 30, 2020

 

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)“). 

 

This Privacy Policy (“Privacy Policy”) explains what data we may collect from our users, how such data may be used or shared with others in connection with the Services, as well as when you visit our website available at: https://www.sayollo.com/ (“website”) as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) https://wwww.sayollo.com/CCPA

 

This Policy is an integral part of our Terms of Use available at https://www.sayollo.com/terms (“Terms of Use”), and any agreement executed between us and our Business Partners. Therefore, we encourage you to carefully review it. Capital words not defined in this document will have the meaning given to them in the Terms of Use. 

In the event, you are a California resident and the CCPA apply to you – please review our CCPA Privacy Notice 

 

THE 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.

  • Children under the age of 16 are not permitted to use the Services or provide us with any Personal Data. 

  • You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data, all as detailed under this Policy. 

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 Policy, please send us an email to privacy@sayollo.com

 

LAWFUL BASIS 

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: 

  1. We process some Online Identifiers (as defined below) based on legitimate interest/consent provided by the users either to Business Partner or to us (depending on the purpose of processing the data).  

  2. Where a Business Partner uses our Services, we process its Personal Data in order to perform our contract with the Business Partner;

  3. 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. 

 

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 / Information”: 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 / Information”: 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:

 

Type of Data

How Do We Use It?

For EU Individuals - Legal Basis under the GDPR

Online Identifiers

Our SDK is a piece of software that is integrated into various Business Partners’ Apps and allows our Business Partners to provide users with video content and advertisements, as detailed above. We collect through the SDK online identifiers such as Advertising ID (Android device), IP address, Mac address and IDFA (iOS device) (“Online Identifiers”).

We will use this data in order to match the appropriate advertisement to the user's device. In addition, we will use this data under our legitimate interest in operating, providing, maintaining, protecting, managing, customizing and improving our Services and the way in which we offer them; auditing and tracking usage statistics and traffic flow; and calculating payments from our Business Partners. 

 

Please note that, any interaction you make with our Business Partner’s content is governed by the applicable providers’ policies, terms and conditions, so we advise you to refer to their privacy policies to learn more about their data collection and protection practices.

 

The necessity of processing for the purposes of providing our Services and of our legitimate interests, and your consent, where required under applicable law.

Technical Data

While interacting with the Services, we will collect technical Non-Personal Data transferred from the user’s devices such as type of operating system, type of browser, type of device, approximate geographical location (i.e. country), user’s 'click-stream' etc. 

We use this data for our Services and website operation purposes. 

The necessity of processing for the purposes of our legitimate interests, and your consent, where required under applicable law.

Business Partner’s Data

 If you are our Business Partner’ during the course of our engagement you will provide us with certain data such as name, contact details, etc.

 

 

 

 

 

We will use this data for the purpose of performing a contract Business Partner’s contact details will be used in order to send needed information related to the Services and our business engagement (e.g., send a welcome message, notify regarding any updates to our Services, send applicable invoices, etc.) and additional occasional communications and updates related to the Services, as well as provide tips related to our Service, promotional and marketing emails. We may also use the information in order to verify identity.

Performance of a contract and the necessity of processing for the purposes of our legitimate interests.

Contact Information 

In the event a user contacts us for any inquiries, by sending us an email, through the online form available on the website, or by other means of communication we make available, it will be requested to provide us with its contact details such as name and email address.

We will use this data solely for the purpose of responding to the user's inquiries and provide the requested information.

Performance of a contract and the necessity of processing for the purposes of our legitimate interests.

Newsletter 

In the event a Business Partner or visitor of our website will sign up to receive our newsletter or other marketing materials, it will be requested to provide certain information such as name and email address. You can unsubscribe at any time using the unsubscribe option within the body of the applicable email or by contacting us directly. We will use Mailchimp services for our email marketing. Please Mailchimp’s privacy policy for more information: https://mailchimp.com/legal/privacy/

We will use this data solely to send the newsletter and other requested marketing materials. 

Your consent.

Recruitment 

If you are interested in working with us, you may voluntarily send us your CV through the applicable button located on the website.

Recruiting is voluntary, and you determine the extent of the 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.

The necessity of processing for the purposes of our legitimate interests, and where applicable, your consent.

 

HOW WE COLLECT DATA

Depending on the nature of your interaction with the Services, we may collect data from you, as follows:

  1. Automatically – we may use the SDK, web beacons, pixels, cookies, and other similar tracking technologies to gather some information automatically. 

  2. 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. 

  3. 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 the collection of Personal Data, or obligate our Business Partners to obtain such consent, and always offer the choice to opt-out. 

COOKIES & TRACKING TECHNOLOGIES

We use cookies or similar tracking technologies when you access the website or interact with the Services we offer.  This use is standard industry-wide practice. 

Cookie

A "cookie" is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes. 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.

  • Analytics, 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 the performance of the content available in the website. We further use this information to compile reports and calculate payments in the course of the relationship with our business partners which their services are displayed on our website. 

  • 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) 


The table details specifics the cookies and other tracking technologies (ours and third party’s) we currently use, the purpose of use, their Privacy Policy, and opt-out controls:

Third-Party

Purpose

Privacy Policy

Facebook

Targeting & Advertising

https://www.facebook.com/about/privacy/update
https://www.facebook.com/policies/cookies/

Wix

Essential, Functionality, Operation. & Security Cookies

https://www.wix.com/about/privacy

Analytics, Measurement & Performance Cookies

Google Analytics

Analytic, Measurement and Performance

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

 

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, however, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited. 

Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful: Google ChromeFirefox; Internet Explorer; Safari; Edge; Opera

You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services like the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page; 

 

Other tracking Technologies options to opt-out: 

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

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

Opt-out provided by Business Partners

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 (see our contact details below), and we will make efforts to assist you. 

 

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; 

  • If the Company organizes the operation of the Services within a different framework, or through another legal structure or entity, or if the Company is acquired by, or merged into or with another entity, provided, however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;

  • 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. 

 

DATA RETENTION 

 

Data Sets

Retention Period

Online Identifiers 

Deleted following to the completion of use and not later than the following 60 days. 

Contact Details 

Deleted Immediately following the completion of a request.

Business Partner Data

According to applicable laws. 

Technical Information

For as long as needed to perform the 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

We use security techniques to prevent your information from being accessed without authorization, improperly used or disclosed, unlawfully destructed or accidental loss, as detailed in our Information Security policy: https://www.sayollo.com/security. If you believe that your privacy was treated not in accordance with this Privacy Policy, or you have a reasonable concern with that any person attempted to abuse our Service, please contact us at privacy@sayollo.com.


Further, in the event of a security incident, in which we discover your Personal Data may be at risk, we will make reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).

USER RIGHTS 

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 the erasure of your Personal Data; right to restrict processing of your Personal Data; the right to object to the 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 and the CCPA, please review our Data Subject Rights Overview.

 

You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here and send it to our privacy team at privacy@sayollo.com.

 

Please note that - 

  • We may request additional information from you when you contact us in order to verify your identity and locate your data.

  • It may take time to process requests in a way that is consistent with applicable privacy law and detailed in the Data Subject Rights Overview.

  • Under the CCPA your rights only apply to the Personal Data collected 12 months prior to the request and you are not entitling to submit more than 2 requests in a 12 months period.

  • 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

We may store or process your information in the US or in other countries. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the 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. 

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 

The Services are not directed or intended for individuals under the age of 16, and we do not knowingly collect or solicit information from children. If we become aware that a child under that age has provided us with Personal Data, we take steps to remove such information from our servers. If you are aware that a child has provided us with Personal Data, please contact us at privacy@sayollo.com.

AMENDMENTS 

This Privacy Policy may change from time to time and we will post the amended terms and make reasonable efforts to provide notification regarding major changes. The last revision will be reflected in the “Last Updated” date above. Amended terms will take effect immediately. Hence, you should review the Privacy Policy periodically to remain informed of any changes. 

 

COMMENTS AND QUESTIONS

If you have any comments or questions about our Privacy Policy, please contact us at: 

Sayollo Media Ltd.

12 Eli Horovitz St., Rehovot, Israel.

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our privacy team at: privacy@sayollo.com

Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.

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; 

  • If the Company organizes the operation of the Services within a different framework, or through another legal structure or entity, or if the Company is acquired by, or merged into or with another entity, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;

  • 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.

 

Data Retention

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

We use security techniques to prevent your information from being accessed without authorization, improperly used or disclosed, unlawfully destructed or accidental loss, as detailed in our Information Security policy: www.sayollo.com/security If you believe that your privacy was treated not in accordance with this Privacy Policy, or you have reasonable concern with that any person attempted to abuse our Service, please contact us at: privacy@sayollo.com


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:

Mobile opt-out:

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

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

 

Cookies opt-out:

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: privacy@sayollo.com and we will be happy to assist you.

User Rights

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: privacy@sayollo.com.

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.

 

Amendments

This Privacy Policy may change from time to time and we will post the amended terms and make reasonable efforts to provide notification regarding major changes. The last revision will be reflected in the “Last Updated” date above. Amended terms will take effect immediately. Hence, you should review the Privacy Policy periodically to remain informed of any changes.

 

Transfer of Data

We may store or process your information in the US or in other countries. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your information 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.

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

You represent and warrant that: (i) if you are located in the US, you are at least 13 years of age; or if you are located in the EU, you are at least 16 years of age; or if you are a resident of any other jurisdiction, you are above the age defined as “child” under applicable laws (collectively “Child” or “Children”); and (ii) you are of legal competence to enter into this Privacy Policy. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from Children. If we become aware that a Child under that age has provided us with Personal Data, we take steps to remove such information from our servers. If you are aware that your Child has provided us with Personal Data, please contact us at privacy@sayollo.com.

Comments and Questions

If you have any comments or questions about our Privacy Policy, please contact us at:

Sayollo Media Ltd.

2 Oppenheimer St., Rehovot, Israel.

You can also contact us via email at: privacy@sayollo.com. If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our privacy team at: privacy@sayollo.com.

Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.

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