- Information Company Collects and Receives;
- How Company Uses Your Information;
- Sharing Information with Third Parties;
- Third-Party Content;
- Social Networks;
- Cookies and Other Technologies;
- Your Rights;
- Information Obtained from Other Companies;
- Data Retention;
- Transfer of Data Outside Your Territory;
- Information Security;
- Do Not Track;
- Notice to Californian Residents – Your California Privacy Rights;
- How to Contact Company.
Information Company Collects and Receives. When you Use the Software & Services, we automatically collect and store the following types of information:
- Technical Information. Certain technical information regarding your device, and your Use of the Software & Services and other third party software and applications installed on your device (the “Other Software”), including the device type and version number, the type, name and version of operating system and Other Software including, without limitation, their interactions with the Software & Services, ISP (Internet Service Provider), hardware version, location, Internet protocol (IP) address, anonymous user identifiers such as cookies and similar web technologies, device configuration, version of the Software & Services, and your configuration and settings of the device and the Software & Services, including language and time zone;
- Usage Information. Certain usage related information regarding your use and interaction with your device, including the Software & Services and Other Software, such as when and how you Use the Software & Services and Other Software, how you use your internet browser and internet search related applications, your language settings, the web pages you visit, applications you use and the content you see, access and utilize on such web pages and applications; for example, offerings and advertisements that you view, use and access, how you use them and your response to them (ie. clickstream data), how frequently you use them, your search queries and the non-precise location, time and date of your searches;
- Support Related Information. If you communicate with us via our support section or via email, we may also collect your email address, name and any information voluntarily submitted by you in connection with such support (for example, your name, company name, and particular support query or request).
- IP Address;
- Install-ID (for installations of specific software such as Browser Extensions);
- Cookie Id;
- URL Referrer;
- Search terms; and
- Support Related Information.
We consider this information to be PII, meaning that without this information, we would not reasonably be able to identify you. Company processes this information on the basis that it is a data controller of the PII. This is how we use this information:
- To provide you with the search services and functionality, including providing you with the search results of our web search partners in response to your online search queries. We delete this data once our fraud and lifetime value assessment has been completed (as discussed in the next paragraphs). For this purpose, Company processes this information on the basis of a legitimate interest of an individual’s right to freedom of expression, including the freedom to hold opinions and to receive and impart information and ideas.
We will share search term and your IP address with our search partners who provides you with certain aspects of the search services and functionality, including the results of your search queries.
- To detect and prevent fraud on its Software & Services.
Company needs the combination of IP Address, Cookie Id, Install-ID, URL and Search Term to conduct fraud detection on potentially fraudulent and illegal uses of the Software & Services. We need this information for 3 months to conduct this fraud analysis. Following this 3 month period, we will delete all data except for the Cookie-ID and Install-ID which we use for business performance which we discuss in the next paragraph. For this purpose, Company processes this information on the basis of a legitimate interest for preventing fraud. In performing fraud detection and prevention, we use the services of third parties who will receive and access your PII.
- To assess the lifetime value of a user.
In our experience, business performance in search is measured over a 24 month period, including, the lifetime value of a users that use our Software & Services. For that purpose, Company retains the Cookie-ID and Install-ID and the number of search queries performed (but not the actual search query itself) performed by each ID for a period of 24 months from the initial collection. For this purpose, Company processes this information on the basis of a legitimate interest for its business operations and internal due diligence.
- Customer Support.
We also use Support Related Information you provide to us to provide you with support and handle your complaints and feedback. This information will not be connected with any other information collected from you on or through the Software & Services, including, any individual ID generated or collected by us, unless you ask as to. For this purpose, Company processes this information on the basis of a legitimate interest and performance of a contract with you. We will retain this information for the time it takes to provide you with the support you requested and to handle your complaints. We may keep your information for longer periods in case of disputes and other legitimate reasons described in the next section “Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request”.
- Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request.
We use your PII and Support Related Information to take action in case of a dispute involving you in connection with the Software & Services and to enforce the terms and conditions applicable to the Software & Services. We also use your PII to comply with legal and regulatory requirements (e.g., the disclosure of information to law enforcement or tax authorities), and to protect against suspicious or other illegal activities. For this purpose, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of Company’s users, its partners, or the general public). We will also share this information with our professional advisors in the scope of this purpose. We will retain this Personal Information for the amount of time as required by law to fulfill the above purposes. This may include ensuring that we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your PII or dealings. Use of Non-PII Company uses non-PII information it collects for the following purposes:
- To operate and update the Software & Services, including in connection with Software & Services provided to our business partners, and to provide you with existing and new functionality and features of the Software & Services.
- to improve, fix and customize the Software & Services;
- to monitor, analyze and optimize your use of the Software & Services, including analyzing seasonal and annual usage trends and providing certain technical and usage information to our business partners as part of the services we provide; and
- to maintain and improve the quality and operation of the Software & Services, including, monitoring viewability of and interaction with advertisements, search results and other products and services provided by Company.
We retain this information for as long as necessary to fulfill our business and/or operational purposes or comply with a legal request. We may also choose to anonymize parts of your PII so that it can no longer be identifiable or attributable to any person if we want to keep it for longer periods of time than the retention periods set forth above. Additional Sharing of PII with Third Parties. We may also share your information in the following events:
- In the event Company goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred;
- You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
- You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
- You have the right to object, to or to request restriction, of the processing;
- You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- You have the right to object to profiling;
- You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
- You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
- You have the right to know what personal information is being collected about you in the twelve months preceding your request;
- You have the right to request the erasure/deletion of your personal data (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
- You have the right to know whether your personal information is sold or disclosed and to whom in the twelve months preceding your request;
- You have the right to say no to the sale of your personal information;
- You have the right to equal service and price, even if you exercise your privacy rights;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.