1. GENERAL INFORMATION
1.1 Thinkz, including its affiliates (collectively, “we“, “our” or “us” or the ‘Company’, the “Group“) is committed to complying with General European Data Protection (“GDPR“) regulations, including, but not limited, national legislation related with data protection, for the purposes of this Policy.
1.3 Personal data/information is defined as any information that identifies an individual or may reasonably identify an individual with reasonable effort, including without limitation: your name, surname, date of birth, residing address, IP address, email address or telephone number, ID documentation, financial documents as utility bill or bank statements as well as other non-public information about you that is associated with or linked to any foregoing, hereinafter referred to as the “Personal Data” or “Personal Information“. Processing activities include, among others, the collection, use, retention and disclosure of such data.
1.4 Your Personal Data will be processed by us (including any of our agents and/or employees), and (where appropriate) any other company in our company Group and/or our partners and subcontractors, in accordance with this Policy.
In this Policy, you can learn about:
1. GENERAL INFORMATION
2. WHAT INFORMATION WE COLLECT?
4. CONDITIONS FOR PROCESSING OF PERSONNAL INFORMATION
5. WITH WHOM WE SHARE INFORMATION?
6. INTERNATIONAL TRANSFER OF INFORMATION
7. THIRD PARTY TRACKING TECHNOLOGIES
8. THIRD PARTY SERVICES
9. RETENTION OF PERSONAL DATA
10. WHAT ARE YOUR RIGHTS?
11. HOW TO CONTACT US?
2. WHAT INFORMATION WE COLLECT?
We may collect and process the following data about you:
By filling out our contact form, the information you provide shall be used to contact you in order to provide you with a personalized experience of our Services; this information may include, but not limited to the following information: your name, surname, email address, residing address, phone number, details, IP-address, device.
We will use your Personal Information, such as your full name, home address, professional email address, etc., collected by ourselves and/or through our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Company’s group; or (ii) the Company’s business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, LinkedIn messages, SMS telephone marketing purposes.
We will use your Personal Information for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing so, or where we have obtained your affirmative consent.
You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by either: following the links inserted in the promotional emails (e.g., selecting the opt-out link), by the notifications preferences in your personal settings of your account or contacting our customer support (the information is available under the section 11. “HOW TO CONTACT US?” of the Policy or by reaching out to us at [email@example.com]. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
We also collect information which you provide us voluntarily in order to personalize your account or for a specific function, for example, you can provide your gender, date of birth, age, interests as well as other additional information about yourself which you voluntarily provide to us at your discretion for a specific function. In addition, we collect your communication when you respond to communications from us, provide us with feedback, communicate with us via email or share additional information about yourself through your use of the Service.
Information we collect from third parties
We sometimes collect Personal Data from third party service providers which is relevant to the provision of the services, as well as Personal Data which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
Log-in history and technical information
In order to enhance the functionality of the service and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Service; etc.).
We collect information about your use of the service, such as applications’ usage, log files, user activity (e.g. pages viewed, user’s movements, time spent, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Service.
The Services are not designed or directed to persons under the age of eighteen (18) with respect to the use of the Services (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Data collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us (our contact details are available under the “HOW TO CONTACT US?” section).
4. CONDITIONS FOR PROCESSING OF PERSONAL DATA
This section outlines the underlying purposes and legal bases for the processing of your Personal Data:
Purpose: Provision of our Service; support and customer relations. We use your Personal Data, such as your username and email address for customer services purposes as well as to present our Websites and its content to you. This includes, for example, providing and operating the Service, keeping you informed about our last updates or responding to any of your inquiries, as well as your request to exercise your User rights.
Purpose:Improving our Service. We collect and analyze information about you and your usage of our Service to improve the usability and effectiveness of our Service based on User’s common preferences and uses.
Legal base: The legal bases for processing this data are our legitimate interests (Art. 6.1(f) GDPR), in this case – providing and improving our Service.
Purpose: Marketing, advertising and analytics. We use your Personal Data in order to provide you with personalized advertisements, including behavioral advertising when you visit our Service, to market our Service and to gather aggregate usage information for analytics, statistical and research purposes, including notification of promotional offers.
Legal base: The legal basis for processing this data are your consent (when required) and our legitimate interests (Art. 6.1(a), 6.1(f) GDPR). Our legitimate interests in this case are providing you with tailored services, content and advertisements that better fit your interests as well as to promote our Service.
Purpose: Dispute resolution and protection of our legal claims. We collect your Personal Data in order to investigate violation of our policies, enable us to resolve disputes in connection with your use of the Service and to establish and defend our legal claims.
Legal base: The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to establish and defend our legal claims.
Purpose: Corporate transactions. We may share your Personal Data with a potential purchasers, successors or investors in the Company or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to the Company.
Legal base: The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR).
Purpose: Prevention of fraud or violation of our policies. We may process your Personal Data to detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Service, including by identifying risks associated with your activity on our Service. We may also investigate any violations of our policies and enforce them.
Legal base: The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to protect our Company and other Users against fraud.
Purpose: Compliance with applicable laws. We process your Personal Data to comply with our various legal obligations such as adult content legislation (where applicable), anti-money laundering, identity verification (e.g., suspicion of minor using our Service), prevention of fraud, complying with data subject rights etc.
Legal base: The legal basis for processing this data is to comply with our various legal obligations (Art. 6.1(f) GDPR) and our legitimate interests.
Special Categories of Personal Data
Our processing of your Personal Information would not involve special categories of personal data for the provisions and improvement of our Service (as defined under Article 9 of the GDPR). We will only process such information, as well as disclose it to competent authorities (law enforcement bodies), where it is strictly necessary and required for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act; (ii) prevention of dishonesty, malpractice or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes.
5. WITH WHOM WE SHARE YOUR INFORMATION?
We may share your Personal Data with other third-party providers when you request a service, which we offer partly or fully through a third-party provider. Third-party providers have a contractual relationship with us. We are taking reasonable measures to ensure that these third-party providers maintain the same privacy standards as us, and we only transfer data to states outside the European Economic Area, provided the recipient guarantees a standard of data protection comparable to the GDPR.
One of said third party providers we use to perform due diligence checks on new and existing customers is TransUnion, and you can find information regarding their Privacy Notice at https://www.transunion.co.uk/legal-information/bureau-privacy-notice.
We share Personal Data with any of the following recipients:
- Companies within our group and other affiliated companies;
- Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
- Payment service providers, payment processors and banks;
- To any third parties who provide services in relation to the operation or promotion of the applicable in-house brand;
- Auditors, contractors or advisers of any of our group’s business processes;
- To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
- Governmental and regulatory bodies, in accordance with applicable laws and regulations; and
- Storing such information on our behalf, for example by using cloud computing service providers;
- Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
- Performing research, technical diagnostics or analytics;
- Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see below, under “Marketing”); and
6. INTERNATIONAL TRANSFERS
For more information about the transfer of your personal data outside of the EEA, our contact details are available under the section 11. “HOW TO CONTACT US?”.
7. THIRD PARTY TRACKING TECHNOLOGIES
We may use third-party advertising technology across our Websites to serve advertisements when you visit or use our Service. We use and authorize third parties to use web beacons, pixels, scripts, tags and other technologies (“Tracking Technologies”).
The Tracking Technologies automatically collect information about you, your online behavior on the Websites, and your device (for example your computer or mobile device), for different purposes, including improving and personalizing your navigation on our Service and enhancing our Service’ performance. Third parties may use this information to provide you with targeted content.
We also allow third parties to collect information about you through Tracking Technologies.
For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third party ad networks operated by NAI and DAA members, please visit their respective websites: https://thenai.org/opt-out/ and www.aboutads.info/choices.
8. THIRD PARTY SERVICES
Please be advised that such third party websites, services or applications are independent from us. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services.
You should always review their privacy practices carefully before providing Personal Data to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
9. RETENTION OF PERSONAL DATA
If you have registered with an account through our services, we will retain your Personal Data during the period your account is active. In addition, we will retain your Personal Data for additional periods, to enable us to meet its legal obligations under applicable laws or regulations, such as the applicable Know-Your-Customer and Anti-Money Laundering regulations.
In addition, we may retain your Personal Data for longer periods, provided that retaining such information is necessary for our legitimate interests, such as fraud prevention and record keeping.
If for any reason you wish to delete your Personal Data, please send us an e-mail to: [firstname.lastname@example.org], and we will make reasonable efforts to address your request.
10. WHAT ARE YOUR RIGHTS?
You have certain rights regarding the collection and processing of Personal Data. To the extent these rights apply to and concern you, you may exercise them by contacting us via the contact details available under the section 11. “HOW TO CONTACT US?” and exercise the following rights:
- (1) Rights of access and data portability – You may obtain a copy of the personal data held by the Company about them at any time and also the right to request that said data is transferred to a third party;
- (2) Right of rectification – In the event that the data held about you by the Company is inaccurate, incomplete or outdated, you may request the rectification of said data (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
- (3) Right of erasure – You may at any time request that the Company erases data held about them by sending an email to the Company as outlined in this policy. You are, however, advised that with the deletion of their personal data, the customer might not be able to use the Service anymore or the account might be totally closed;
- (4) Right to restriction of processing, objection to processing and withdrawal of consent – You may at any time request that the Company restricts or ceases to conduct certain data processes provided that there exists no other lawful basis on which the Company is authorized to process said data;
- (5) Right to lodge a complaint – All requests, complaints or queries may be addressed to the Company to the following email address; [email@example.com] with the subject ‘Privacy’. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve this. You can also file a complaint with the Data Protection Authority should you not be satisfied with the way in which we handle your Personal Information.
Please note that these rights are not absolute and we will use commercially reasonable efforts to honor your request, but please note that we may be legally or otherwise required to comply with any applicable legal requirements, including any legal and ethical reporting or document retention obligations. You should be aware that unless you have registered and created an account on the Websites, we may not be able to respond to your request as we do not have sufficient information to identify you. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies. Similarly, we may ask you to provide us with additional information in order to adequately verify your identity upon your request.
11. HOW TO CONTACT US?
Thinkz is a company incorporated in Tel Aviv and having its registered address at Igal Alon 114, Tel Aviv. For any privacy or data protection queries, the company’s Data Protection Officer can be reached via email on [firstname.lastname@example.org] with the Subject ‘Privacy’. We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
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