Persona.ly DSP Privacy Policy

When using a Publisher Property, you allow us to provide you with personalized content, including advertisements. In addition, by using the Publisher Property, Users grant the Publisher with permission to collect the Device Information (as defined below) and share it with Persona.ly pursuant to the acceptance of the Publisher Property privacy policy. This information we collect and transfer includes non-sensitive device information (collectively referred to as “Device Information”), such as:

• Approximate geolocation data;
• Carrier, ISPs;
• Device properties such as: operating system, operating system version;
• User’s clickstream;
• Internet browser used to access the Publisher Property; and
• Certain identifiers such as user′s IP addresses or Android ID or Advertising ID or IDFA (″Identifiers″). Note that the Identifiers are considered ″Personal Information″ in many jurisdictions (such as the EEA), therefore, we treat the Identifiers as such and comply with applicable laws.

Persona.ly uses the information it collects about you to provide the Services and to gain a better understanding of the products and services that may interest you and other Users. We may use your information in order to:

• enhance your experience with the Services;
• to operate, provide, maintain, protect, manage, customize and improve our Services;
• to optimize the content served through the DSP based on the User’s preferences, uses and interactions with the Services;
• perform research, as well as for analytical and statistical purposes;
• to respond to your inquiries and provide you with requested service when you contact us or register to our Newsletter, as well as inform our Business Partners about our services, such as upcoming changes or improvements;
• protect our or third parties’ rights or property, resolve disputes and enforce our policies;
• to audit and track usage statistics and traffic flow, audit our affiliates, calculate payments and detect fraud, security or technical issues in connection with the Services;

Depending on the nature of your communication with us, we may collect the above detailed information from you, as follows:

• automatically, including through the use of cookies (as detailed below), or other similar tracking technologies when a user interacts with a Publisher Property; or
• when you voluntarily choose to provide us with information, i.e. when you contact us, register to our newsletter, etc., all as detailed in this Policy. Whenever technically possible and required under applicable law, we will ask for your consent to collect your Personal Information and offer you the choice to opt-out.

When you access or use the Service, we may use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your device (i.e., locally stored) and which will allow us to customize the Service and content as well as enhance your experience of the Services.

The cookies and similar technologies used by us are created per session and do not include any Personal Information, other than your preference, navigation on the applicable Publisher Property as well as the session key and allow us to analyze trends, track users’ movements around the Site, which are removed as your session ends. Most browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your experience may be limited.

For more information about cookies and your controls in this regard, you may review the following links:

• https://support.google.com/chrome/answer/95647?hl=en (Chrome);
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
• http://www.opera.com/help/tutorials/security/cookies/ (Opera);
• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
• https://support.apple.com/kb/PH21411 (Safari);
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

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 some features of the Services may not operate properly and your online experience may be limited

Third parties (i.e., Google Analytics) may also use cookies, scripts or web beacons for the purpose of tracking and analyzing your use, this information does not include Personal Information. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend you review Google’s policies located at: www.google.com/policies/privacy/partners. We also encourage you to review the Google Analytics’ currently available opt-outs for the web tool available at: https://tools.google.com/dlpage/gaoptout/

The Service may link to third party content (″Third Party content″). The Third Party Content is not reviewed or examined by us. Persona.ly is not responsible for the Third Party Content or any additional links contained therein nor for the quality or accuracy, fitness for a particular purpose of any content of any such Third Party Content. We make best efforts to ensure the Third Party Content will not harm your experience, however we cannot represent or warrant to such Third Party Content. It is your sole responsibility to comply with the appropriate terms and conditions of the Third Parties Content as well as with any other obligation under privacy, security and export laws related to the use of such Third Party Content. IN NO EVENT SHALL THE PERSONA.LY BE LIABLE TO ANYONE FOR ANY DAMAGE ARISING FROM OR OCCASIONED BY THE CREATION OR USE OF THE THIRD PARTY CONTENT OR THE INFORMATION OR MATERIAL ACCESSED-THROUGH THESE THIRD PARTY CONTENT.

Persona.ly will not share the Personal Information it collected with any third parties or any of its partners except in the following:

• Authorized Disclosures. We may disclose your Personal Information to third parties when you consent to a particular disclosure of your Personal Information. Please note that once we share your information with another company, that information becomes subject to the other company′s privacy practices. In addition, we may share Identifiers, for the purpose of operating our business and providing the Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the Services.


• Compelled Disclosures. To the extent required, Persona.ly will share Personal Information to comply with any applicable law, regulation, legal process or governmental demand (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required in order to enforce our policies (including our policies and agreements) including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues. In addition, we will share your information, solely to the extent required to establish or exercise our rights to defend against legal claims or 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.


• Service Providers. We may disclose Personal Information to our service providers in order for such service providers to perform requested services on our behalf.


• Business Transfers. We may share Personal Information, in the event of a corporate transaction. In the event of the aforementioned, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.


• Non-Personal Information. We may share aggregate or Non-Personal Information with our Business Partners and additional third parties in accordance with the terms of this Policy. We may store Non-Personal and Personal Information on our servers or our cloud servers, use or share Non-Personal Information in any of the above circumstances, as well as for the purpose of providing and improving our Service, aggregate statistics, marketing and conduct business and marketing analysis, and enhance your experience with the Publisher Property.

Your principal rights under applicable data protection law in relation to your Personal Information are as follows:

• the right to access any information which is provided by you;
• 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; and
• the right to withdraw consent.

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Information. Depending on your relationship with us, to exercise your rights contact us at: support@persona.ly. Note that we may require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take up to one (1) month in accordance with applicable law. 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.

If you would like additional information about the choices please contact us at: support@persona.ly or contact our Data Protection Officer at: joseph@persona.ly.

Even after providing your consent to this Policy, you are entitled to change your mind. If you do, you may easily opt out of the data collection, sharing process and targeted advertising services related to our Service. Please note that even if you opt-out, you will still receive content and advertising from Persona.ly. Opting-out just means that the advertisements you do receive from us will not be targeted in any sort of way.

Options to opt out:

• Learn how to opt-out from Android - https://support.google.com/ads/answer/2662922
• Learn how to opt-out from iOS – https://support.apple.com/en-il/HT205223
• You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
• You may opt out of certain advertisers′ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative′s (″NAI″) website- NAI consumer opt-out and the Digital Advertising Alliance′s (″DAA″) website- DAA opt-out page.
• If you wish to opt out of interest-based advertising, you may click here. Please note you will continue to receive generic ads.
• Our Publishers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for the Publisher Property to learn more about the privacy practices of our Business Partners. Please note, however, that we are not responsible for the privacy practices of our Publisher, or other third parties.

In the event, that you have any additional complaints about your privacy rights, please initially contact the Data Protection Officer. Please note that you have the right at any time to contact your local data protection authority.

You may also Contact Us at: support@persona.ly and we will be happy to assist you. Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer.

You represent and warrant that, (i) if you are located in the US, you are at least 13 years of age; or if you are located in any other GEO, you are above the age defined as ″child″ under applicable laws in your jurisdiction (collectively ″Child″ or ″Children″); and (ii) you are of legal competence to enter into this Privacy Policy. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we obtain actual knowledge that a User is considered as a Child under applicable law, we will take steps to immediately delete such User′s Personal Information. If you become aware or have any reason to believe that a Child has shared any information with us, please contact us at: support@persona.ly.

Your privacy is very important to Persona.ly and we are committed to protecting your Personal Information from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For additional information regarding Persona.ly′s security measures please see: www.persona.ly/security. In addition, some of the data collected by the Company is stored in the AWS data servers, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security/. Furthermore, some of the data collected by the Company is stored in the Digital Ocean′s data servers, for more information regarding the data security provided by Digital Ocean, please see: https://www.digitalocean.com/security/

Persona.ly also protects your privacy by seeking to minimize the amount of data that we store on our servers in the first place. If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse Persona.ly please contact us at: support@persona.ly directly.

Further, in the event of a data breach, in which we discover your Personal Information is at risk, we will notify you and the applicable authority (if required subject to applicable laws).

We retain the Non-Personal Information we collected for as long as needed to provide the Service and to comply with our legal obligations, resolve disputes and enforce our agreements. Persona.ly will retain data collected for online behavioral advertising for as long as commercially useful to carry out its business purpose, in accordance with applicable laws, or until an individual expresses an opt-out preference. Further, we retain the Personal Information, we collected for as long as legally permissible, in accordance with applicable laws. Persona.ly may rectify, replenish or remove incomplete or inaccurate information, at any time and at its sole discretion.

As a part of an international group, we may store or process your Personal Information in the United States or in other countries. 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.

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

If you have any requests regarding the data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: joseph@persona.ly.

Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.

WE RESERVE THE RIGHT TO PERIODICALLY AMEND OR REVISE THIS POLICY, AT OUR SOLE DISCRETION. THE MOST RECENT VERSION OF THE POLICY WILL ALWAYS BE POSTED ON THE SITE. IF WE DO MAKE ANY CHANGES, THE UPDATED DATE AT THE TOP OF THE POLICY WILL BE REFLECTED IN THE “LAST REVISED” HEADING. IF WE MAKE ANY MATERIAL CHANGES, THAT WILL SUBSTANTIALLY AFFECT YOUR USE OF THE SERVICE OR THE DATA COLLECTION BY US, WE WILL PROVIDE YOU WITH APPLICABLE NOTIFICATIONS OR BY MEANS OF A NOTICE ON THIS SITE. WE ENCOURAGE YOU TO REVIEW THE POLICY PERIODICALLY TO ENSURE THAT YOU UNDERSTAND HOW WE COLLECT, USE AND SHARE INFORMATION THROUGH THE SERVICES. ANY CHANGES TO THE POLICY WILL BECOME EFFECTIVE IMMEDIATELY UPON THE DISPLAY OF THE REVISED POLICY. YOUR CONTINUED USE OF THE PUBLISHER PROPERTY OR SERVICES FOLLOWING THE DISPLAY OF SUCH REVISED POLICY, CONSTITUTES YOUR ACKNOWLEDGEMENT AND CONSENT OF SUCH AMENDMENTS AND YOUR AGREEMENT TO BE BOUND BY THE TERMS THEREIN.

If you have any questions or comments about this Policy, please write to us at:

O.P Vision LTD dba Persona.ly
Meir Weissgal Rd. 2, Rehovot
You can also contact us via email at: support@persona.ly.