[Last Modified: December 29, 2019]

This privacy policy (“Privacy Policy”) provides detail on how we, Vizulit Ltd. (“Vizulit”, “Company”, “we”, “us”, or “our”) collect, process and use data from visitors of our website, available at: https://www.vizulit.com/  or users of our Services, including business partners downloading our Vizulit app (respectively “App” and “user” or “you”). This Privacy Policy governs our data practices whenever you access or use our Services, and is an integral part of our Terms of Service (“Terms”), or any agreement executed between you and us. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth therein.  

 

This Privacy Policy may be updated from time to time, and every 12 months in the event requires under applicable laws. Therefore, we ask you to check back periodically to read the most updated Privacy Policy. The last and updated version is reflected in the "Last Modified" heading above. In the event of a material change we will make best efforts to provide a notification through our website or Services and if possible, we will send a written notification personally to you, subject to applicable laws requirements. 


If you have any questions about this Policy, please contact us at: Support@vizulit.com

 

  1.  TYPES OF DATA WE COLLECT 
    When you access our website or use our Services, we may collect certain information about you and your use as follows:

    Personal Data” or “Personal Information” (subject to applicable law definitions) - meaning information that identifies an individual or may with reasonable effort identify an individual. This may include online identifiers, name, emails, etc., subject to applicable law.

    Non-Personal Data” - meaning technical and aggregated data about you that is non-identifiable and non-personal (i.e., cannot identify you).

    If we combine Personal Data/Personal Information with Non-Personal Data, we will treat the combined data as Personal Data.

    EU General Data Protection Regulation (“GDPR”) & Lawful Basis for Data Processing 
    We have included below information about which data is processed, how we process and use your data, but before, we would like to explain the lawful basis for which we do so subject to the GDPR:
      1.  Where a user or a business partner registers for any of our Services, we process its Personal Data in order to perform our contract.        In the event you contact us, we will process your contact details and other information you choose to provide us with in order to              perform our contract with you. 
      2.  When visitors access our Services, we collect certain Online Identifiers which we have a legitimate interest in processing such data.
      3.  For direct marketing purposes, we have legitimate interest to process our users email address; or 
      4.  We will also process certain Personal Data where you have provided us with consent to do so, if applicable. 

    As defined under the GDPR, Vizulit acts as a Controller of certain data such as data you provide when you sign up to our Services or contact us. Further, we also act as a Processor of certain data (i.e., data we process for Brand Owners).

    Please see below a table specifying the data we collect and how do we use it:










































































    California Consumer Privacy Act 2018 (“CCPA”) & Categories of Personal Information Collected and Shared
    Please note that, under the CCPA, Personal Information does not include: Publicly available information from government records; Deidentified or aggregated consumer information.

    As required under the CCPA, please see below a table specifying the categories of Personal Information we collect:






























































    As required under the CCPA, please see below information regarding disclosures of Personal Information for a business purpose:
    In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose: 
      F. Internet or other similar network activity.

    We disclose your Personal Information for a business purpose to the following categories of third parties: Service providers
    Business Partners – Brand Owners. 

    When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
     

  2. HOW WE COLLECT INFORMATION 
    Depending on the nature of your interaction with the Services, we may collect information as follows:

    • Automatically – we may use cookies, API and similar tracking technologies (as elaborated in the Cookies & Tracking Technologies Section below) to gather some information automatically. In addition we will receive applicable information from the Brand Owner. 

    • Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through sign up, contact us communications, etc. 


      In the event required under applicable law, we will ask for your consent to collect Personal Data/Personal Information and offer you the choice to opt-out of such collection if we are required to do so in accordance with applicable law. For more information, please refer to the “Your Rights” Section of this Privacy Policy.
       

  3. (COOKIES & TRACKING TECHNOLOGIES
    We may use industry-wide technologies such as “cookies” and other tracking technologies (e.g. web beacons, pixels, etc.) in our website and Services, as we gather certain information automatically, by ourselves or by using third party services. The use of cookies and tracking technologies is a standard industry-wide practice. We use these technologies, for example, to enable automatic activation of certain features, remembering your preferences, and making the interaction between you and our Services quicker and easier. We also use cookies to track how visitors interact with our website and Services to monitor how we are performing. You can find more information about cookies at www.allaboutcookies.org.
    We may permit third parties to use cookies or other technology to collect information about your online and application usage activities across our Services, or use such third party’s technologies in order to provide our Services, as detailed in the table below. The data processed through these third party’s technologies might include Personal Data, thus, we recommend you review the information provided below carefully:



















    Cookies Opt Out: 
    You may opt-out of data collection and sharing process made through cookies. 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. However, if you choose to disable cookies, some features of our Services may not operate properly and your online experience may be limited. For more information about cookies and your controls in this regard, please review your browser settings. You may find applicable information here: 
      1.  Chrome: https://support.google.com/chrome/answer/95647?hl=en;
      2.  Firefox:  https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences ;
      3.  Opera: http://www.opera.com/help/tutorials/security/cookies/ ;
      4.  Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
      5.  Safari: https://support.apple.com/kb/PH21411;
      6.  Edge:  https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

    ​Please note that once you choose opt out, part of the Services provided by us may no longer be available and some features may not work if you revoke the data transfer.
     

  4. WITH WHOM WE SHARE YOUR DATA:
    We do not share any Personal Data collected from you with third parties except in the following events:  Third party service providers: we share your information with third parties that perform services on our behalf (e.g. customer service, tracking, servers, service functionality and support, etc.) these third parties may be located in different jurisdictions; Brand Owners: we will share your Instagram account details (and statistics) with the Brand Owner in order to validate that you are the applicable purchaser and your entailment for Reward; Law Requirement: we will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content of any user suspected to have engaged in illegal or infringing behavior and thereby we may also release your information when we believe release is appropriate to comply with the law, enforce our Services policies, or protect ours or others rights, property, or safety; Policy Enforcement: we will share your information, solely to the extent needed to enforce our policies including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; Company’s Rights: we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims;  Third Party Rights: we will share your information, solely to the extent needed to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights; Corporate Transaction: we may share Personal Data, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy; and Authorized Disclosures: we may disclose your Personal Data to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices. 
    We may share aggregate or Non-Personal Data with our affiliated companies and additional third parties in accordance with this Terms. We may store any type of information on our servers or our cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Services, aggregate statistics, marketing and conduct business and marketing analysis, and to enhance your experience.
     

  5. YOUR RIGHTS
    We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. The principal rights under applicable data protection law in relation to Personal Data are as follows (as applicable to your jurisdiction): the right to access any information which is provided to us; the right to rectification; the right to erasure; the right to restrict processing; the right to object to processing; the right to data portability; the right to complain to a supervisory authority (in the event you are a resident of the EEA); the right to withdraw consent (to the extent applicable); and the right to Non-Discrimination against for having exercised your rights under the applicable laws. 

    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. 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. For more information, including with regards to response timing and format, please review our Privacy Rights Policy https://www.vizulit.com/privacy-rights-policy.

    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.

    We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data/Personal Information, depending on your relationship with us and your jurisdiction. If you wish to exercise any or all of your rights, you may, at any time, make such request by filling out the Data Subject Request (“DSR”) form available here: https://28dcf273-a7c0-4a92-bbc1-dbe439b89b94.usrfiles.com/ugd/28dcf2_dc3af2bbe2c74c86b2f2cdc37dcdca61.pdf, and send it to our privacy team at: privacy-inquiry@vizlulit.com
     

  6. RETENTION
    We retain the information we collect for as long as needed to provide the Service, carry out our business purpose, perform our contract with you, and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its data, as detailed above. We are entitled to rectify, replenish or remove incomplete or inaccurate information, at any time and at our sole discretion. 
     

  7. HOW DO WE SAFEGUARD AND TRANSFER DATA?
    We take great care in implementing and maintaining the security of the website, Service and your information. We employ industry standard procedures and policies and implemented physical, technical and administrative security measures to ensure the safety of our users’ information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access. 

    If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Website or acted in an inappropriate manner, please contact us directly at: privacy-inquiry@vizlulit.com. Further, in the event of a data breach, in which we discover your Personal Data is at risk, we will notify you through the Services or, if technically possible, by sending you an email, subject to applicable law requirements.

    We may store or process your Personal Data in the United States or in other countries. If you visit our website or use our Services from locations outside of the United States, please note that any information you provide to us through your use of our website or Service may be transferred to and processed in countries other than the country from which you accessed our website or Service, including the United States where our central database is operated. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data 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. 
     

  8. DO NOT TRACK DISCLOSURE
    The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/.
     

  9. CHILDREN
    Our Services are not direct or intended for children under the age eighteen (18). Further, we will not knowingly solicit, collect and store Personal Data directly from children, as defined under applicable law, and specifically: (i) US residents under 13 years of age; (ii) EU residents under 16 years of age. If we later obtain actual knowledge that a user is considered as a child under applicable law, we will take steps to immediately delete its Personal Data. We request that such individuals do not provide Personal Data through the Services. If you become aware or have any reason to believe that a child has shared any information with us, please contact us at: Support@vizulit.com
     

  10. CONTACT US
    If you have any questions or comments about this Privacy Policy, or any concerns with respect to how your privacy any information are handled, please contact us at: Support@vizulit.com 
    You may also contact us at:
    Vizulit Ltd.  
    Yigal Alon 114 Tel Aviv, 
    11th floor, postal code 6744320.

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