Last updated: February 13, 2020
Our Commitment to You
Empire Media Network Ltd. and its affiliated companies (“Empire Media”, “us” or “we“) are dedicated to providing its users with the highest level of transparency and control over the use of their data. In order for us to provide you with our services, we are required to collect and process certain personal information about you and your activity.
By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security, and integrity of this Information. We encourage you to review the following information carefully.
- Grounds for data collection
- How do we receive data about you?
- What type of data do we collect?
- Tracking Technologies
- How do we use the data we collect?
- With whom do we share your Personal Data?
- EU Resident
- California Residents
- How do we protect your information?
- How to contact us?
- Our Policy Toward Children
- Updates to this Policy
Grounds for data collection
Processing of your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) is necessary for the performance of our contractual obligations towards you and providing you with our services and the operation of our websites (hereinafter the “Websites” and “Service“), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.
How do we receive data about you?
We receive your Personal Data from various sources:
- Registration information – When you voluntarily provide us with your personal details in order to create an account or register with our Service.
- When you communicate with us – For example when you send us an email, we collect the Personal Data you provided us with.
- Third party information – We may receive your personal data from third-party providers who help us with the provision and maintenance of our Services, such as social networks (for example your name and username, when you register or log-in to our Service), traffic analytics vendors, fraud prevention agencies and others.
What type of data do we collect?
In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Service, and as otherwise indicated in this Policy. We collect the following Personal Data about you:
- Registration information – in order to register and enjoy the full functionality of our Service we may collect the following Personal Data:
- When you register for our service we will collect your email address, name, and phone number.
- You may also register to our newsletter only, in which case we will collect your email address.
- If you connect your account to a social network (for example: if you log in via Facebook or Google+), we may also receive certain details, such as your profile name and profile photo and other social account details.
Please note that although registration is not mandatory, unregistered users may have limited usage of the Service.
- When using our Service – our server will collect your IP-address and unique device identifiers.
We also collect data about the use of our Service and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:
- Technical information – such as aggregated usage information, e.g. your approximate geolocation, page visits, clicks, the browser you are using and its display settings, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), and cookie information etc’.
- Information from third parties – this category includes information we receive from our business partners. This may include pseudonymous advertiser identifiers or aggregated analytical data. This information is also used to enhance data points about a particular unique browser or device.
If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.
When you visit or access our Services we use (and authorize 3rd parties to use) pixels, cookies, beacons and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Web site’s performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.
What are cookies?
Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.
Cookies are widely used in order to make websites work in an efficient way. Cookies remember your preferences and make the interaction between you and the Service smoother and more efficient.
How to manage your cookie settings?
There are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.
- Turning off cookies via your web browser
Most web browsers will provide you with some general information about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third-party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
- Information about cookies is usually found in the “Help” section of the web browser. Below are some links to some commonly used web browsers:
For other browsers, please consult the documentation that your browser manufacturer provides.
- Turning off third-party cookies
You can turn off certain third party targeting/advertising cookies by visiting the following link: Network Advertising Initiative.
How do we use the data we collect?
- Provision of service – for the provision and improvement of our Services, including for support and to respond to your queries.
- Service announcements – we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.
- Analytics, surveys, and research – from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Services and think of new and exciting features for our users.
- Marketing and advertising – We may use your Personal Data in the following ways:
- we or our partners may send you promotional material concerning our Service, or our partners’ services, which we or our partners, believe might interest you; we may also display certain ads or links to our partners’ services on our Service, which we believe will be relevant for you. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Data.
- If you do not want us to use or share your Personal Data for advertising or marketing purposes, you may opt out of certain cookies by following the instructions provided in the “Tracking Technologies” section herein, specific rights are also granted to you if you are an EU or California resident, as detailed below. You may also contact us at any time for any requests or information, using the contact details provided below.
Please note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.
- You may choose not to receive our promotional or marketing emails by clicking on the “unsubscribe” link in the emails that you receive from us. Please note that even if you unsubscribe, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us. You may also object to the use of your Personal Data for advertising purposes by disabling your cookies, as described in the Tracking Technologies section above. Please note we have no control over our partners’ communications, in order to unsubscribe from our partners’ communications please contact the relevant partner, or use the “unsubscribe” link in its emails.
- Protecting our interests – we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of Empire Media, its users and/or partners.
- Enforcing of policies – we may use your Personal Data in order to enforce our policies, including but limited to our Terms.
- Compliance with legal and regulatory requirements – we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
With whom do we share your Personal Data?
- Internal concerned parties – we share your information with companies in our group, as well as our employees, in order to provide you with our services.
- Compliance with laws and law enforcement entities – we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
EU User Rights
You may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
- Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your Personal Data that is in our control.
- Request erasure of your Personal Data.
- Object to the processing of Personal Data by us.
- Request to restrict processing of your Personal Data by us.
- Lodge a complaint with a supervisory authority.
However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.
Transfer of data outside the EU
EU users – please note that some data recipients may be located outside the EU. In such cases, we will transfer your personal data only to such countries as approved by the European Commission as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
Collecting Personal Data
In the preceding twelve (12) months, we have collected the following categories of Personal Data:
|Category of Personal Data Collected||Personal Data Collected||Sources of Personal Data||Business/Commercial Purpose for Collection|
|Identifiers||Full name, email address, IP address, UDID, social network account, Advertiser Identifiers||
Directly from consumers upon subscription.
Directly from consumer’s activity on our Services by cookies or other tracking technologies.
From third parties that interact with us, including social networks and other publicly available sources.
To provide you with our Service.
To announce news or updates regarding our Service.
To conduct surveys or test new features to improve our Service.
For marketing or advertising purposes.
|Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))||Telephone number|
Sharing Personal Data
We disclose your Personal Data to third parties for a business purpose (as it is defined under the CCPA). When we disclose Personal Data for a business purpose, we enter into a contract that describes the purpose and requires both parties to keep that Personal Data confidential and not use it for any purpose except in the performance of the contract.
In the preceding twelve (12) months, we have disclosed the above-mentioned categories of Personal Data with the following categories of recipients for a business purpose:
- Our affiliates;
- Service Providers;
Selling Personal Data
We share some of your Personal Data with our partners to provide our Services and for other commercial purposes. Under the CCPA some of this sharing may be considered a “sale” that you have a right to opt-out of.
If you choose to opt-out of sale, such action may impact how you are able to view and/or receive some services. This is because some of the services we offer require disclosure of your Personal Data to third parties.
In the preceding twelve (12) months, we have sold the following categories of Personal Data:
- Category A – Identifiers;
- Category B – California Customer Records.
You have the right to opt-out of such disclosures of Personal Data, see below for more information on how to exercise your rights.
User Rights under the CCPA
The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.
Access to Personal Data
You may request that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third-parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Data, if applicable.
You have the right to submit a verifiable consumer request that we delete Personal Data collected from you and retained
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.
Right to Opt-Out of the Sale of Personal Data
In the event that we sell your Personal Data, you have the right to submit a request to opt-out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.
After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Service, ensuring that the Service is working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the Personal Data collected when you use those devices or browsers.
Additionally, although clicking the “Do Not Sell My Personal Data” link will opt you out of the sale of your Personal Data for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Data (except for Personal Data sold within 90 days prior to your exercising your right to opt-out) or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/# and the information provided above in the “Tracking Technologies” section of this policy.
Exercising Your Rights
You can exercise your rights by submitting a verifiable consumer request to our email address: firstname.lastname@example.org.
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Data.
The request must:
- Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
- Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may only request a copy of your data twice within a 12-month period.
If you have any general questions about the Personal Data that we collect about you and how we use it, please contact us at email@example.com.
Response Timing and Format
Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Data in a format that is readily useable and should allow you to transmit the information without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.
Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
You can designate an authorized agent to make a request under the CCPA on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How do we protect your information?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access to your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.
While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the service, and you do so at your own risk.
We will retain your Personal Data for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take 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. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.
How to contact us?
If you wish to exercise any of the aforementioned rights or receive more information, please contact us using the details provided below:
- Empire Media Network Ltd.
- Email: firstname.lastname@example.org
- 28, Ehad Ha’am St. Tel-Aviv, Israel
Our Policy Toward Children
We understand the importance of protecting children’s privacy, especially in an online environment. The Site and Services are not designed for or directed at children under the age of 16 years old (“Minors”). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided above.
Updates to this Policy