2. THE PRODUCTS AND SERVICES WE PROVIDE
3. THE TYPES OF PERSONAL DATA WE COLLECT
4. HOW WE USE USER’S INFORMATION
5. DISCLOSURE OF USER’S INFORMATION TO THIRD PARTIES
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
7. HOW WE SAFEGUARD USER’S INFORMATION
8. HOW LONG WE KEEP USER’S PERSONAL DATA
9. USER’S RIGHTS
10. DESIGNATED REPRESENTATIVE
11. QUESTIONS AND CONCERNS
1.1 PushStakes with its registered office at Emma Tauber 5, Hertzeliya, Israel. PushStakes is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
(A) “Customer” a publisher who own/controls/operates Internet assets (such as Websites) (“Publisher Assets”) who incorporates PushStakes Products in his assets (“Publisher”) or an advertiser who provides us with content to be served through PushStakes Products and/or Publishers assets (“Advertiser”), or with whom PushStakes has a contractual relationship.
(B) “Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, PushStakes (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of PushStakes or any other person in respect of an individual.
(C) “PushStakes”, “we or “us” means PushStakes.
(E) “User” a person making any use of PushStakes Website and/or PushStakes Products.
2. THE PRODUCTS AND SERVICES WE PROVIDE
(A) Information we receive through our websites (“PushStakes Websites”);
(B) Information we receive through our products (“PushStakes Products”);
(C) Information we receive through our support or cloud-based services (“PushStakes Services”).
2.2 Personal Data may be collected from (a) PushStakes Websites – for example with respect to personnel of our Customers engaging us through the PushStakes Website; (b) PushStakes Products – for example when a User interact with Publisher assets.
3. THE TYPES OF PERSONAL DATA WE COLLECT. Many of the services offered by PushStakes require us to obtain Personal Data about a User in order to perform the services we have been engaged to provide. In relation to each of the services described at Section 2.1 above, we will collect and process the following Personal Data about the Users –
3.1 Information that a User provide to PushStakes. This includes information about Users that they provide to us. The nature of the services Users are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
(A) basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);
(B) Any information that a User choose to share on PushStakes internet forums which may be considered Personal Data. (Please note that PushStakes does not collate information included on PushStakes internet forums together with Personal Data from a User Center account or profile);
3.2 Information that we collect or generate about Users. This includes (by way of non-exhaustive list):
(A) A file with Users’ contact history to be used for enquiry purposes so that we may ensure that Users are satisfied with the services which we have provided to them;
(B) Information on the internet usage or browsing habits of Users of Publisher Assets (e.g. what websites or pages were visited by each User, any advertisements viewed by Users and resulting actions such as visits to other websites); and
(C) The internet browser used, the internet device operating system and device ID, IP address (from which geo location may be extracted to a level of a city)
3.3 Information we obtain from other sources.
· When Users visit PushStakes Websites, use PushStakes Products and/or Publisher Assets, cookies are used to collect technical information about the services that they use, and how they use them.
· For more information on the cookies used by PushStakes please see our Cookie Notice.
(B) Anonymized data. In addition to the categories of Personal Data described above, PushStakes will also process further anonymized information and data that is not processed by reference to a specific individual.
3.4 Information we get from third parties: The information we collect comes mainly directly from Users or as a result of Users’ browsing habits. Sometimes we might collect personal data about Users from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about Users, in order to better inform, personalize and improve our services, and to validate the personal data Users provide.
4. HOW WE USE USERS’ INFORMATION
4.1 Users’ Personal Data may be stored and processed by us in the following ways and for the following purposes:
(A) to understand Users needs and interests;
(C) To communicate with Users in order to provide them with services or information about PushStakes and PushStakes Products;
(D) To allow Users to use and access the functionality provided by the PushStakes Products and/or PushStakes Website.
(E) To assess Users’ application for PushStakes Products and/or PushStakes Website, where applicable;
(F) To set up Customers to use PushStakes Products and/or PushStakes Website;
(G) To set up Users to use the User Centre and/or PushStakes Website;
(H) To personalize the User experience;
(I) for the management and administration of our business. For example – (i) to respond to User’s requests and support PushStakes Costumers or Users needs more efficiently; (ii) to administrate payments;
(J) For the administration and maintenance of databases storing Personal Data;
(K) To conduct analysis required to detect malicious data and understand how this may affect the User and/or our IT system;
(L) For statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
(M) To offer User(s) with content PushStakes believes may interest such User(s), such as targeted advertising content or other commercial information;
(N) In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
Research and development
(O) for ongoing review and improvement of the information provided on PushStakes Websites to ensure they are User friendly and to prevent any potential disruptions or cyber-attacks;
(P) To understand feedback on PushStakes Products and to help provide more information on the use of those products and services quickly and easily;
(Q) For in-depth threat analysis;
(R) To improve PushStakes Services, PushStakes Products and/or PushStakes Website and develop new products services and websites
4.2 However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:
(A) We have obtained Users’ consent;
(B) We have legal and regulatory obligations that we have to discharge;
(C) We may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
(D) The use of Users’ Personal Data as described is necessary for our legitimate business interests, such as:
· allowing us to effectively and efficiently manage and administer the operation of our business;
· We need to do so in order to perform our contractual obligations with our customers;
· maintaining compliance with internal policies and procedures;
· monitoring the use of our copyrighted materials;
· enabling quick and easy access to information on PushStakes Products;
· offering optimal, up-to-date security solutions for mobile devices and IT systems; and
· obtaining further knowledge of current threats to network security in order to update our security solutions.
5. DISCLOSURE OF USERS’ INFORMATION TO THIRD PARTIES
5.1 We may share Users’ Personal Data outside of the PushStakes group for the following purposes:
(A) With our business partners (such as PushStakes Customers). For example, this could include our Advertisers whose content Users choose to interact with and Publishers who’s Publisher Assets Users interact with. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
(C) if we sell our business or assets, in which case we may need to disclose Users’ Personal Data to the prospective buyer for due diligence purposes; and
(D) to the extent required by law, for example if we are required to disclose Users’ Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
(E) If we are acquired by a third party, in which case the Personal Data held by us about Users will be disclosed to the third party buyer.
(F) 3rd Party Data Co-Processors – Data may be shared with services utilized as co-processors for services related to your account, including payment processors or live chat support. Intercom is our data processing partner.
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
6.1 PushStakes is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer Users’ Personal Data to locations outside of Users’ country.
6.2 Where we transfer Users’ Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:
(A) the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data (Israel is an approved country);
(B) the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
(C) Where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
(D) In other circumstances the law may permit we to otherwise transfer Users ‘Personal Data outside Europe.
6.3 Users can obtain more details of the protection given to their Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of Users’ Personal Data) by contacting us as described in Section 12 below.
7. HOW WE SAFEGUARD USERS’ INFORMATION
7.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems.
7.2 As a condition of employment, PushStakes employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by an PushStakes employee is prohibited and may result in disciplinary measures.
7.3 When Users contact a PushStakes employee about their file, they may be asked for some Personal Data. This type of safeguard is designed to ensure that only a User, or someone authorised by the User, has access to their file.
8. HOW LONG WE KEEP USER PERSONAL DATA. How long we will hold Users’ Personal Data for will vary and will be determined by the following criteria:
8.1 The purpose for which we are using it – PushStakes will need to keep the data for as long as is necessary for that purpose; and
8.2 legal obligations – laws or regulation may set a minimum period for which we have to keep Users’ Personal Data.
9. USERS RIGHTS
9.1 In all the above cases in which we collect, use or store Users’ Personal Data, Users may have the following rights and, in most cases, Users can exercise them free of charge. These rights include:
(A) the right to obtain information regarding the processing of Users’ Personal Data and access to the Personal Data which we hold about them;
(B) The right to withdraw Users’ consent to the processing of Users’ Personal Data at any time. Please note, however, that we may still be entitled to process Users’ Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
(C) The right to request that we rectify Users’ Personal Data if it is inaccurate or incomplete;
(D) In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which Users have provided directly to PushStakes;
(E) The right to request that we erase Users’ Personal Data in certain circumstances. Please note that there may be circumstances where Users ask us to erase their Personal Data but we are legally entitled to retain it;
(F) The right to object to, or request that we restrict, our processing of Users’ Personal Data in certain circumstances. Again, there may be circumstances where Users object to, or ask us to restrict, our processing of Users’ Personal Data but we are legally entitled to refuse that request; and
(G) The right to lodge a complaint with the relevant data protection regulator if Users think that any of their rights have been infringed by us.
9.2 Users can exercise their rights by contacting us using the details listed in Section 12 below.
10. THIRD PARTY CONTENT.
11. CHILDREN’S PRIVACY
The PushStakes Products and/or PushStakes Website content is intended for adults and we will not knowingly collect personal information from children under 16 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 16, we will make reasonable efforts to delete such information from our records. If a User is the parent or legal guardian of a child under age 16 who they believe has submitted personal information to the PushStakes Products and/or PushStakes Website, They should contact us immediately.
12. QUESTIONS AND CONCERNS. If you have any questions or concerns about PushStakes’s handling of your Personal Data, or about this Policy, please contact our Privacy Officer using the following contact information:
Email Address: finance@PushStakes.com
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Privacy Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, PushStakess’ Privacy Officer will provide you with the contact information for that regulator.