- access or visit our website (“Visitors”) available at: www.cyfluencer.com;
- use and sign up for our Cyfluencer platform (“Platform”) to either publish its content or blog posts (“Publisher Content” and“Publisher(s),” respectively) or to access and repost Publisher Content on their social media account (“Influencer(s)”). Publisher and Influencers shall be referred to collectively herein as “Partner(s)”; and
- click on the Publisher Content that is displayed by the Influencers (“Viewers”).
The website and the Platform shall be referred to collectively herein as the “Services”. Additionally, Visitors, Partners and Viewers shall be collectively referred to herein as “you” or “your”.
We have included information below regarding which types of data are collected and how we process and use your data. However, before we get into that, we would like to explain the lawful basis upon which we collect, process and use your data (as further explained in the table below):
- If you are a Partner, we will process your Personal Data (as such term is defined below) in order to perform our contract with you;
- If we have a legitimate interest in processing Personal Data, such as for direct marketing or for security and verification purposes, when you access our website or as part of our Services; or
- We will also process your Personal Data where you have provided us with your consent to do so if and as required under applicable law.
For the purposes of the European Union General Data Protection Regulation (“GDPR”), we are considered the Controller (as such term is defined under the GDPR) of the Personal Data we collect from our Visitors and Partners and considered the Processor (as such term is defined under the GDPR) of the Personal Data that we process from the Viewers.
If you are a resident of California, the California Consumer Privacy Act (“CCPA”) may apply to you. Please review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA.
INFORMATION WE COLLECT
We may collect two types of data from you, depending on your interaction with us.
- Non-Personal Data: The first type of data is non-identifiable, anonymous and aggregated data that is mainly technical data transmitted by your device and via your use of the Services. (“Non-Personal Data”). We are not aware of the identity of the individual who we collected the Non-Personal Data from.
- Personal Data: The second type of data is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).
For the avoidance of doubt, any Non-Personal Data that is connected or linked to any Personal Data shall be considered Personal Data for as long as such connection or linkage exists. Furthermore, you are not required by law to provide us with any information and may choose to avoid providing us with certain Personal Data.
Information we collect from Visitors:
|Type of Personal Data||Purpose of Processing and Lawful Basis|
In the event you contact us for support or other inquiries, either through the online form available on the website, by sending us an email or by any other means of communications that we make available to you, you may be requested to provide us with your full name and email address.
We will process this information subject to our legitimate interest and use it solely for the purpose of contacting you, responding to your inquiries and providing you with the support or information that you requested.
We may process the contents of our correspondence with you in order to improve our customer service and in order to resolve any disputes with you (if applicable).
If you voluntarily subscribe to our newsletter, you will be asked to provide us with your full name and email address. You can unsubscribe at any time by using the unsubscribe option within the body of the applicable email correspondence or by contacting us via email.
We use this information, based on your consent, solely in order to provide you with the content that you requested to receive.
|Online Identifiers and Technical Non-Personal Data|
When you access our website or use our Services, we may, either directly or indirectly (through our third-party service providers) collect your IP address.
We may collect technical Non-Personal Data from you when you access our website or use our Services as well, such as, your language preference, your “click stream” and the actions you took when you visited our website or used our Services.
In the event required under applicable law, we will obtain your consent to gather such information, for example, when we collect this information via cookies (as further explained below).
Please note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address. Your IP address may be collected by our third-party analytic partners that offer ways to opt-out of such collection, all as explained below.
In addition to the Personal Data included in the Visitors table above, if you are our Partner we will also process the Personal Data included in the Partners table below.
Information we collect from Partners:
|Type of Personal Data||Purpose of Processing and Lawful Basis|
When you register for our Services via our website or via social media (i.e., Facebook, Twitter and LinkedIn), you may need to provide us with your full name, company name and the general geographical location (i.e., country level) of your company (if you are a Publisher), job title, email address and/or social media account details at the time of registration. If you are an Influencer, you will need to provide us certain information regarding your social media account whether or not you choose to register for our Services via such social media account for example, the name of the social media platform, number of followers, and a link to your social media account. We will also have access to publically posted profile information from your social media account.
In addition, we may process your Personal Data for our legitimate interests, for example, to send you marketing and promotional messages and offers related to our Services. You are able to unsubscribe from receiving such correspondence from us by clicking on the designated link in the applicable message that we will send you or by contacting us at: email@example.com.
Please note that if you choose to unsubscribe from direct marketing, we may still retain your contact details and send you relevant service-related information such as invoices and service rates.
As part of the Services you may be required to provide us with your payment details (including your PayPal UID, credit card information or bank account information). The payment details may be processed by us or our third party service providers
This information will be processed for the purpose of performing our contract with you and will enable you to use our Services.
Information we collect from Viewers:
|Type of Personal Data||Purpose of Processing|
|IP Address, Geographical Location, and Technical Non-Personal Data.|
We will process your IP address when you click on any of the Publisher Content that is posted on an Influencer’s social media account. Additionally, we will process some of your technical Non-Personal Data including the type of operating system you use, type of browser you use, the time and date you accessed the Publisher Content, the type of device that you use, as well as your approximate geographical location.
We will use this data in order to operate, provide, maintain, protect and manage our Services. As explained above, we are considered the Processor of this information and our Partners are considered the Controller. This data will be processed under our Partners legitimate interests to perform research, and conduct associated analytical and statistical activities, detect fraud, security or technical issues in connection with the Services and calculate payments for and to our Partners. Please note that, we do not attempt to analyze or determine your identity based on such information. Your IP address may be collected by our third-party analytic partners that offer ways to opt-out of such collection, all as explained below.
HOW WE COLLECT DATA
Depending on the nature of your interaction with us, we may collect information from you in one or both of the following ways
SHARING INFORMATION WITH THIRD PARTIES
Wadi Digital will not share any Personal Data it collects with any third party, other than under the following circumstances:
- Compelled Disclosures – To satisfy any applicable law, regulation, legal process, subpoena or governmental request;
- Security Detections – To detect, prevent, or otherwise address fraud, security or technical issues;
- Service Providers – To collect, hold or manage your Personal Data through our authorized third-party service providers, as reasonable for our business purposes;
- Explicit Consent – If you provide us with your explicit approval to share your information prior to the disclosure.
COOKIES POLICY AND TRACKING TECHNOLOGIES
A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.
The third-party cookies used on our website are as follows:
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 block or erase cookies your online experience may be limited.
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual requests to opt-out of such collection, subject to applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.
Depending on your jurisdiction, data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we process (please review our User Rights Policy for more information regarding the rights you may have under the relevant data protection and privacy laws in your jurisdiction).
If we are unable to provide you with the information that you asked for, 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. 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.
We take great care in implementing and maintaining the security of your information. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any of such. We have implemented technical, physical and administrative security measures to protect your Personal Data, including without limitation by using industry standard encryption. In addition, we limit access to your Personal Data on our servers. The data collected by us is stored mainly on Digital Ocean’s data servers in Frankfurt, Germany. Please visit the following link for more information regarding the data security provided by Digital Ocean.
We may store or process your Personal Data in the EU, the United States or in other countries. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our website. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data that was collected within the European Economic Area (“EEA”) is transferred outside the EEA, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer
- By email: firstname.lastname@example.org.
- By mail: Wadi Digital Ltd. Gush Chalav 24/1 Pardes Hannah-Karkur, Israel