(Last Update: March 2023)
AbsoluteHistory is an online magazine (“Website”) owned and operated by ContentIQ (“Company”, "we" or “us” or “our”). We respect your privacy and recognize that your privacy is important.
TYPES OF DATA COLLECTED AND PURPOSES:
Depending on your interaction with us, we may collect two types of data from you:
“Non-Personal Data” meaning aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services. We are not aware of the identity of the user from which the Non-Personal Data is collected. Such Non-Personal Data may include aggregated usage information and technical information transmitted by your device, such as browser version, operating system type and version, mobile network information, device settings, and software data.
“Personal Data” (as defined under the GDPR) or “Personal Information” (as defined under the CCPA) meaning individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual.
For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health, government identifiers, precise geolocation or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).
The table below details the types of Personal Data we collect, the methods and purpose of such collection, and our lawful basis for processing such Personal Data (where the GDPR applies):
|DATA TYPE||METHODS AND PURPOSE||LAWFUL BASIS|
|Website Interaction and Marketing
When you interact with our website, we may collect your online identifiers, such as Internet Protocol (IP) address and Cookie ID, unique identifiers (“Online Identifiers”).
|Online Identifiers and cookies are used in particular to operate the website and enable its proper functionality, for example to automatically recognize you by the next time you enter the website or to confirm you are a real person.||Strictly necessary cookies (as described in the Cookies and Similar Technologies section below) which are required for the proper and basic operation of the website will be processed in our legitimate interests, where such cookies collect Personal Data on our behalf.
Other cookies, to the extent these collect your Personal Data, will be based on your consent which we will obtain through our cookie notice and consent mechanism.
If you voluntarily contact us, through any means of communications we make available (for example, “contact us” page) for support or other general inquiries you will be required to provide us with certain information such as your name, your organization name (i.e., on behalf of which you contact us), email address, and any additional information you decide to share with us (“Contact Information”).
|We process such data to respond to your inquiry, and provide you with the support, materials and information you have requested.
The correspondence and its contents with you may be processed and stored by us in order to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).
|We process Contact Information subject to your consent. Further processing may be subject to our legitimate interest, for example for internal documentation and improvement of service purposes.|
When you sign up to our newsletter or other marketing materials, you will be requested to provide your name and email address.
|We will use your email address in order to send you our newsletter and other marketing materials.
||We process such data subject to your consent. You may withdraw consent at any time through the “unsubscribe” link within the email or by contacting us directly at: firstname.lastname@example.org.
||We may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Website, to enforce our legal terms and conditions, to protect the security or integrity of our databases, and to take precautions against legal liability.||Such processing is based on our legitimate interests, which in this case are protecting our Services and data, exercising our legal rights, and complying with our legal obligations.|
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. The transfer of Personal Data to third party countries as further detailed in the Data Transfer Section is based on the same lawful basis as stipulated in the table above.
We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Website and Platform, as detailed above.
HOW WE COLLECT YOUR INFORMATION:
- When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.
COOKIES AND SIMILAR TECHNOLOGIES:
The cookies we use on are website are:
|ccpa_opt_out||ContentIQ||User requests||1 year|
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. You may set your browser to block all cookies, including cookies associated with our Website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Below is a list of useful links that can provide you with more information on how to manage your cookies:
- Google Chrome;
- Mozilla Firefox;
- Safari (Desktop);
- Safari (Mobile);
- Android Browser; and
- Microsoft Edge
You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third-party webpages:
- The Interactive Advertising Bureau (US);
- The Interactive Advertising Bureau (EU); and
- European Interactive Digital Advertising Alliance (EU)
Additionally, you may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising. You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:
- On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).
- On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).
Please note that once you choose to opt out or disable cookies, some features of the Website may not operate properly, and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however it will not be targeted content or advertising.
For additional information, please see the User Rights and Opt-Out section below.
DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your Personal Data with third parties, including our Advertisers and service providers that help us maintain our Website. More information about the categories of such third-party recipients is described below:
|CATEGORY OF RECIPIENT||DATA THAT WILL BE SHARED||PURPOSE OF SHARING|
|Service Providers||All types of Personal Data.||We may share aggregate or Non-Personal Data with our affiliated companies and additional third parties in accordance with the terms of this Policy. We may store any type of data on our servers or 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 Website, aggregate statistics, marketing and conduct business and marketing analysis, and to enhance your experience.|
|Consent Manager (“CMP”)||Online Identifiers and the user’s preference.||When you browse our Website for the first time, depending on your location, a CMP will appear, where you will be able to choose if you allow us and our partners to implement tracking technologies, and where applicable, to share Personal Data (e.g., Online Identifiers) with third parties for one or all of the aforesaid purposes (“Preference”). These Preference are different depending on your jurisdiction. The CMP receives the Online Identifiers from us.|
|Media Buyers||Cookie ID
|In some cases when we buy media online, we may submit unique identifier. The unique identifier provided to the media owner, may become personally identifiable when such media owner combines our parameters with its own existed information about you, to which you gave your consent when first interacting with such media owner’s services (for example social media services).|
|Any acquirer of our business||All types of Personal Data||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 Policy.|
|Legal and law enforcement
||Subject to law enforcement authority request.||We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.|
|Affiliated Companies||All types of Personal Data||We may share aggregate or Non-Personal Data with our affiliated companies and additional third parties in accordance with the terms of this Policy. We may store any type of information on our servers or 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.|
|Advertisers||Online Identifiers and End User Data.||Enabling Advertisers to display ads or content that best suit such web-page, as a part of our Services.|
|Publishers||Unique identifiers, IP address, user activity data (interaction with Ads)||We share this Data through reports which includes analytic, performance of ad campaigns, ads viewed and clicked in an aggregated way, as well as for and security purpose (such as fraud detection).|
We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
When we share information with services providers, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Data they receive and to use the Data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).
USER RIGHTS AND OPT-OUT OPTIONS:
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. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
the following table describes all the rights you are entitled to. Please note that some rights are only available for residents of California. For more information regarding your rights as a California resident, please see the CCPA-Related Information section below or visit https://oag.ca.gov/privacy/privacy-laws..
|EU Residents Right||California Privacy Right||Details|
|Right to know or access Personal Data collected by us||The right to know what Personal Information the business has collected.||The right to know what Personal Data we collected, including the categories of Personal Data, the sources from which the Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Personal Data, the categories of third parties to whom we disclose Personal Data, and the specific pieces of Personal Data the we collected about you.|
|Deletion Rights||The right to delete Personal Data that we collected from you, subject to certain exceptions.|
|Correct Inaccurate Data||The right to correct inaccurate Personal Data that we maintain about you|
|N/A||Opt-Out of Sharing for Cross-Contextual Behavioral Advertising||You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising” (all as defined under the CCPA), often referred to as “interest-based advertising” or “targeted advertising”.|
|N/A||Opt-out from selling||The right to opt-out of the "sale" or "sharing" (as defined under the CCPA) of Personal Information.|
|N/A||Limit the Use or Disclosure of Sensitive Personal Information (SPI)||You have the right to request to limit the collection of your, to that use which is necessary to maintain our Website;|
|Opt-Out of the Use of Automated Decision Making||N/A||In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information.|
|N/A||Non-Discrimination||The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.|
|Data Portability||You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.|
|Restriction or Objection to Processing||N/A||You have the right to object the processing of your Personal Data, unless certain exceptions apply.|
|Withdrawal of Consent||N/A||If Personal Data is processes on the basis of your consent, you have the right to withdraw it at any time.|
Exercising Your Rights
your rights may be exercised by using the Data Subject Request Form, which includes instructions for submitting, the general description of the process, verification requirements, when applicable, and any information the consumer or employee must provide.
Certain rights can be easily executed independently by you without the need to fill out the Data Subject Request Form:
- If you are our Publisher, you can correct certain data provided under your Publisher Account (such as contact information) through the account settings;
- You can opt-out from receiving our emails by clicking the “unsubscribe” link available in the email itself.
- You can use the cookie settings tool on our website to change your preferences.
- You can opt out of interest-based advertising with some of the service providers we use, such as Google and Google Analytics. Please note that if you opt out of interest-based advertising, some information will still be collected for other purposes such as analytics, and internal operations. You will also continue to receive contextual advertisements, but they may be less relevant to your interests.
- You can use our "Do Not Sell Or Share My Personal Information" link, located at the bottom of our homepage.
- You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulatory services. For more information, please visit:
- Digital Advertising Alliance (US) HERE
- Digital Advertising Alliance (Canada) HERE
- Digital Advertising Alliance (EU) HERE
- Network Advertising Initiative HERE
- Digital Advertising Alliance App Choices HERE
- Use the Global Privacy Control (“GPC”) signals. Ad choices settings will vary depending on your browser and device settings. Please note that your opt-out choices will only apply to the specific browser or device from which you opt out. We encourage you to explore your device and browser settings to better understand your choices.
- Use the Global Privacy Control (“GPC”) signals. Ad choices settings will vary depending on your browser and device setting. Please note that such opt-out choices will only apply to the specific browser or device from which you opt-out. We encourage you to explore your device and browser settings to understand your choices better.
In general, Personal Data usually will not be retained for more than 24 months. However, we do retain the data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable laws, or until you express your preference to opt-out, where applicable.
The retention periods are determined according to the following criteria:
- where we have a valid a business reason to process your Personal Data, such as the provision of our service.
- where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements;
- for us to have an accurate record of your dealings with us in the event of any complaints or challenges;
- if we reasonably believe there is a prospect of litigation relating to your Personal Data.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so. However, retention periods will be determined by taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time and in a way that prevents the Data from being restored or reconstructed.
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards, such as encryption using SSL, minimizing the amount of data that we store on our servers, restricting access to Personal Data by AbsoluteHistory employees, contractors, agents, etc. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty that we will always be able to prevent such access.
Please contact us at: email@example.com if you feel that your privacy was not managed properly, or if you become aware of an attempt by a third party to gain unauthorized access to your Personal Data. We will make a reasonable effort to notify you and the relevant authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
INTERNATIONAL DATA TRANSFER:
We operate globally, and any information that we collect, disclose or share, including (but not limited to) your Personal Data, can be stored and processed in the European Economic Area, United Kingdom and United States, for the purposes detailed in this Policy. To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to data recipients:
- located in the EEA or in the UK;
- located in non-EEA countries or UK which have been approved as providing adequate level of data protection by the European Committee; or
- who have entered into a legal agreement ensuring an adequate level of data protection, including the Standard Contractual Clauses as approved by the European Committee.
INTERACTION WITH THIRD PARTY WEBSITES:
ELIGIBILITY AND CHILDREN PRIVACY:
The Website is not intended for use by individuals under the age of majority, as defined by the applicable law in such individual's jurisdiction of residence ("Minor"). AbsoluteHistory does not knowingly process Minor's information and will discard any data we receive from a user that we find or reasonably suspect to be a Minor immediately upon discovery. Please contact us at: firstname.lastname@example.org if you have reason to believe that a Minor has shared any data with us.
This information applies to Personal Information of users who reside in the State of California (“Consumers” as defined under the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act of 2020 ("CPRA") and will be referred herein as “you”).
Personal Information is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device.
Personal Information does not include: Publicly available information that is lawfully made available in government records; information that a consumer has made available to the public; De-identified or aggregated consumer information, and information excluded from the CCPA’s or CPRA’s scope such as Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA);clinical trial data, and any Personal Information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
Collection, disclosure and sharing of Personal Information
In the preceding twelve (12) months, we have collected the following Personal Information:
Category A- Identifiers: a real name, unique personal identifier, online identifier, Internet Protocol address, email address.
Category B- Internet or other similar network activity: information on a consumer's interaction with a website
Category C- Geolocation data approximate location derived from IP address or movements.
We collected such Personal Information from the following categories of sources:
- Directly and indirectly from activity on our website: For example, directly from you when you inquire about our website, or indirectly, we collect your usage data automatically from measurement tools.
- Directly from you: For example from forms you complete, contact us, and etc.
- Indirectly from you: we track your activities across the internet, for example, when you view or interact with certain content, web page or ad.
- From third-parties: For example, from vendors who assist us in performing services for consumers, advertising networks, internet service providers, data analytics providers, social networks, and data brokers.
We may use the Personal Information collected for the following purposes:
- To fulfill or meet the reason you provided the Personal Information (support, respond to a query, etc.)
- To improve our Website
- To analyze which types of ads should be provided in our Website
- To maintain our Website
- For marketing our Website
- For analyzing your use of the Website
- To respond to law enforcement
- To enforce our policies, to defend from claims or exercise our legal rights
- Any other reason detailed in this Policy.
We will not collect additional categories of personal information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We do not "Sell" personal information, as this term is defined under the CCPA.
In the preceding twelve (12) months we:
- Disclosed your Personal Information. 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 the performance of the contract. We also prevent the recipient from selling or sharing your Personal Information.
- Shared your personal Information. Sharing is defined as sharing your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our Partners to serve such personalized content.
|Categories of Recipients||Disclosed/ Shared||Purpose|
|Cloud computing and storage vendors||Disclosed||storage, hosting|
|Government entities/ law enforcement||subject to a law request|
|Operating systems||operating the services|
|Analysis providers||providing analytic data on the use of our website and services. we limit the providers ability to share such information, as detailed above.|
|Programmatic||measurement and reporting|
|Marketing providers, CRM providers, social networks, advertising networks.||marketing which is not cross-contextual, ad delivery.|
|Service providers||improving the services, development, and optimization|
|Ad-network||Shared||share for cross-context behavioral advertising.|
Exercising Your Rights Under the CCPA
As mentioned above, your rights may be exercised by using the Data Subject Request Form, which includes instructions for submitting, the general description of the process, verification requirements, when applicable, and any information the consumer or employee must provide.
In addition to the information provided under the User Rights and Opt-Out Options section above, we provide option to opt out of Sharing for Cross-Contextual Behavioral Advertising or Selling Personal Information by using the following opt-out options:
- By using the “do not sell or share my information” footer on our website or click here.
- Through Device-Level Choices: if you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device settings.
- Opt-Out through Industry Consumer-Choice Platforms: you can make choices about data collection for certain companies which participate in such tools, by visiting an industry consumer-choice platform, such as the NAI or DAA or EDAA.
- By turning on a recognized opt-out preference signal, such as the Global Privacy Control (“GPC”) signals.
Please know that opting out of interest-based advertising does not mean that you will not receive advertising. You may still receive ads, but those ads may be less relevant to your interests.
“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:
- When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:
- Provide the authorized agent signed permission to do so or power of attorney.
- Verify their own identity directly with the business.
- Directly confirm with the business that they provided the authorized agent permission to submit the request.
- We may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
We do not offer financial incentives to consumers for providing Personal Information.
We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median or mean number of days in which we responded to such requests, in the previous year (these metrics are compiled annually and refer to the period between July 1st of the previous year to July 1st of the following year):
|Request||Num. of Requests Received||Num. of Requests Complied with (and Whether In Whole or In Part)||Num. of Requests Denied||Mean or Median Number of Days for Response|
|Requests to delete|
|Requests to know|
|Requests to opt-out of selling/sharing|
|Requests to limit|
Other California Obligations
- Direct Marketing Requests: California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form.
- "Do Not Track" Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS:
Nevada law requires certain businesses to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of Personal Information that the business has collected or will collect about the consumer. Nevada law defines "sale" as the exchange of Personal Information for monetary consideration by the business to a third party for the third party to license or sell the Personal Information to other third parties. If you are a Nevada consumer from whom ContentIQ has collected Personal Information and you wish to submit a request relating to our compliance with Nevada law, please contact us at email@example.com. You may also submit a request to opt-out by clicking the "Do Not Sell My Personal Information" link located in the footer of the Website, or by submitting a Data Subject Request.
This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.
- By the “contact us” page available here;
- By Mail: HaArba'a St. 17, Tel Aviv-Yafo, Israel
- By Email for general inquiries: firstname.lastname@example.org
- By Email for our privacy team: email@example.com
Data Protection Representative: ContentIQ has designated Dr. Andreas Mätzler as its representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. Inquiries regarding ContentIQs EU privacy practices may be sent to Dr. Mätzler at Schellinggasse 3/10, Vienna 1010, Austria, or by e-mail to firstname.lastname@example.org (please add the following subject to all correspondences: 14102729). If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
DATA PROTECTION OFFICER:
The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. If you have any questions about this Policy, please contact our Data Protection Officer:
HaArba'a St. 17, Tel Aviv-Yafo, Israel