Persona.ly SDK Privacy Policy

[Last Revised: June 6, 2018]

O.P Vision LTD dba Persona.ly (“we” “us” “our” or “Persona.ly”) is a global mobile ad-tech company that provides its mobile application developers, advertisers and publishers (“Business Partners”) with an advertising platform for the purpose of delivering targeted and personalized advertising to individuals (“User(s)”) who download, use or otherwise interact with an App Developer’s app or our Services, as defined below (hereinafter the “Business Partners” and “User(s)” shall be collectively defined as “you” or “yours”).

Our technology enables us or our App Developers (as defined below) to show Users personalized and optimized advertising that is based on Users’ interests and behaviors. In order to provide these Services, we collect and use certain information about Users’ activity and preferences, all as detailed in this Privacy Policy (“Policy”).

Persona.ly recognizes the importance of your privacy and we take this issue very seriously. To this end, we have designed the Persona.ly Privacy Policy in a format that is easy to read so that you can clearly understand our privacy practices. We are committed to treating any information we collect with care and respect.

This Policy describes Persona.ly’s collection and use of the information provided or collected on or through our various services and features (collectively shall be defined hereinafter as the “Services”): our website which is currently located at www.Persona.ly (“Site”) as well as our Software Developer Kit (“SDK”) which is implemented within Persona.ly’s app developer partner or publisher’s (“App Developer”) mobile application (“App” or “app”) for the purpose of displaying advertisement or to respond on a surveys, install apps, watch videos, etc. (collectively, “Offer Wall”).

We have included below information about which data is collected, how we process and use your data, but before, we would like to explain the basis on which we do so:

  1. Where you sign up for any of our services, we process your personal data in order to perform our contract with you;
  2. If we have a legitimate interest in processing data, such as for direct marketing or online identifiers when you access our Website; or
  3. We will also process your personal data or sensitive where you have provided us with consent to do so.

TYPES OF INFORMATION WE COLLECT

The first type of information is non-identifiable information which may be made available or gathered via your use of the app or the Services, to clarify, we are not aware of your identity (“Non-Personal Information”).
The Non-Personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including: (i) certain software and hardware information (i.e., operating system, type of device, internet service provider, etc.); (ii) approximate geo-location.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes either (i) your email address and contact information such as your name and phone number which you submitted voluntarily; or (ii) certain identifiers such your IP addresses or Android ID or Advertising ID, IDFA, user agent or Device ID (“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.

Please note that we may collect different categories of Personal and Non-Personal information from you depending on the nature of your interaction with the Services, in the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

The third type of information may include information that can be considered as sensitive data, such as your social demographic information, gender, marital status, education, ethnicity/race (where permitted by applicable law), employment related information. Note that we will collect this data solely if you provide it to us voluntarily through an Offer Wall survey that you have decided to fill in and provide this data (“Personal Sensitive Data”).

INFORMATION WE COLLECT FROM BUSINESS PARTNERS

If you are one of our Business Partner, we may collect the following information from you:

INFORMATION WE COLLECT FROM USERS

The Persona.ly’s SDK, which is integrated into an app, is software that allows our Business Partners to provide you with personalized content, including advertisements and Offer Walls. By downloading and using the app, Users grant the App Developer with permission to collect such device information and share it with Persona.ly pursuant to the acceptance of the App Developer’s privacy policy.

Persona.ly collects the information set forth below for the purpose of creating a user profile in order to deliver targeted advertisements through the Services. This information includes Personal and Non-Personal Information as defined above, all as follows: Approximate geolocation data; ISPs; Device properties such as: operating system, operating system version, device type; Name of the app; List of installed apps on User’s android device. Please note that Persona.ly hashes such list of installed apps; Internet browser used to access the Services; and 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.

Further, as detailed above, if you choose to fill in a survey through the Offer Wall you may provide personal and Personal Sensitive Information such as your contact details, address, ethnicity, health information, etc. this is not required and is provided by you solely in you free will. This information may be shared with the applicable sample market research company (“Research Partner”) for which you submit the survey. The Research Partner may share this information with other partners in an aggregated form with a unique identifier that will not be identified with you as a person. Further, this Privacy Policy will govern the transfer and process of Personal Sensitive Information by us and not by the Research Partner. Prior to providing the Personal Sensitive Information on the applicable Offer Screen we recommend you review the privacy policy of the Research Partner available therein.

USE OF YOUR INFORMATION BY PERSONA.LY

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:

HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the Services, Persona.ly may collect information from you automatically or when you voluntarily choose to provide us with information such as through the registration process or filling out a survey, all as detailed in this Policy. We may also collect certain types of information automatically, including through the use of Cookies, Web Beacons and other similar tracking technologies (as detailed below). Persona.ly primarily collects information from Users when an App Developer serves an advertisement to a User by using the Persona.ly SDK, as detailed above.
For additional information regarding choices you may have with respect to our use of your information, please refer to the Your Choices and Controls section of the Policy.

DATA COLLECTION BY THIRD PARTIES

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 app 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.
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/.

THIRD PARTY CONTENT

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.

SHARING YOUR INFORMATION WITH OTHER COMPANIES

Persona.ly will not share the Personal Information it collected with any third parties or any of its partners except in the following:
(a) 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. (b) 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. (c) Service Providers. We may disclose Personal Information to our service providers in order for such service providers to perform requested services on our behalf. (d) 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; (e) Research Partners. We may share your Personal Information or Sensitive Personal Information to our Research Partners in order to determine your eligibility to the survey; or (f) 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 App and Service, aggregate statistics, marketing and conduct business and marketing analysis, and enhance your experience with the App.

YOUR CHOICES AND CONTROLS

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

  1. the right to access any information which is provided by you;
  2. the right to rectification;
  3. the right to erasure;
  4. the right to restrict processing;
  5. the right to object to processing;
  6. the right to data portability;
  7. the right to complain to a supervisory authority; and
  8. 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: victor@persona.ly.

TARGETED ADVERTISING OPT OUT OPTION

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:

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.

CHILDREN’S PRIVACY

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.

DATA SECURITY AND INTEGRITY

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).

DATA RETENTION

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.

TRANSFER OF DATA

As a part of an international group, we may store or process your Personal Information in the United States or in other countries. Furthermore, we may transfer your Personal Information to Research Partners outside of the EEA. 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.

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/.

DATA PROTECTION OFFICER

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: victor@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.

MODIFICATIONS AND UPDATES

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 APP 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.

MARKET RESEARCH

Persona.ly may share your personal information and/or social-demographic information, including, without limitation, a unique identification number (“UID”), postal code, gender, marital status, education, ethnicity/race (where permitted by applicable law), employment related information, and non-personally identifiable information on household members, with third party sample/market research companies (individually each a “Third Party MR Company” and collectively the “Third Party MR Companies”) for the following purposes:

  1. Identifying client survey opportunities that you may be eligible for through the Third Party MR Companies; and
  2. Disclosing such data elements to clients of the Third Party MR Companies for audience measurement services; and
  3. Appending such data elements to completed client surveys and delivering the appended survey data to clients of the Third Party MR Company(ies) for analytical or research purposes; and
  4. Other uses as set forth in their privacy policy.

If you are eligible for a client survey opportunity offered through a Third Party MR Company, the Third Party MR Company will provide your unique identification number and a survey link to us and we will invite you to participate in the client survey through our Offer Wall. We will not share your name, email address, or phone number with the Third Party MR Companies. In connection with the sharing of your information with a Third Party MR Company, your information may be transferred and stored outside of your country of residence, including, without limitation, in the United States, and by agreeing to this privacy policy you are agreeing to the processing and exportation of your personal information as set forth in this Section. If you have any questions about this data sharing or should you choose to opt-out, please contact us at support@persona.ly. If you opt-out, it is the responsibility of Persona.ly to inform the Third Party MR Companies. Please note that Persona.ly is solely liable and responsible for managing all opt-out requests. Your participation in such survey opportunities does not entitle you to any benefits offered by, or membership with, the Third Party MR Companies.

CONTACT US

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.