Information Company Collects and Receives.
When you Use the Software & Services, we automatically collect and store the following types of information:
How Company Uses Your Information.
Use of PII
As stated above, we collect the following information from you:
The following describes how we use such information (also, the “Purpose”):
Company uses each of the following, and in some cases, the combination of IP Address, Cookie Id, Install-ID, URL Referrer and Search Term to conduct fraud detection on potentially fraudulent and illegal uses of the Software & Services, in both the Use of the Software & Service, and on the business to business serving and measurement level. We need this information for 3 months to conduct this fraud analysis. Following this 3 month period, we will delete all data except for the Cookie-ID and Install-ID which we use for business performance analysis as described in the next paragraph. For this purpose, Company processes this information on the basis of a legitimate interest for preventing fraud. In performing fraud detection and prevention, we use the services of third parties who will receive and access your Personal Information as described in this Section 2.
We retain the Cookie-ID and Install-ID and the count of search queries (but not the actual search query itself) performed by each such ID for a period of 24 months from the initial collection. We use such information to analyze performance, fix errors, and improve the usability and effectiveness of the Software & Services. For this purpose, Company processes this information on the basis of a legitimate interest for its business operations and internal due diligence.
We also use Support Related Information you provide to us to provide you with support and handle your complaints and feedback. This information will not be connected with any other information collected from you on or through the Software & Services, including, any anonymous internal identifier generated or collected by us, unless you ask us to or it is required in order to process your request. For this purpose, Company processes this information on the basis of your consent, by actively reaching out to us, and voluntarily providing us with the information of your choice. We will retain this information for the time it takes to provide you with the support you requested and to handle your complaints. We may keep your information for longer periods for service recording purposes, or in case of disputes and other legitimate reasons described in the next section “Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request”.
We use your PII and Support Related Information to take action in case of a dispute involving you in connection with the Software & Services and to enforce the terms and conditions applicable to the Software & Services. We also use your PII to comply with legal and regulatory requirements (e.g., the disclosure of information to law enforcement or tax authorities), and to protect against suspicious or other illegal activities.
For this purpose, we may share your information with law enforcement or other competent authorities and any third party, as may be required (e.g to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of Company’s users, its partners, or the general public). We will also share this information with our professional advisors in the scope of this purpose. We will retain this Personal Information for the amount of time as required by law to fulfil the above purposes. This may include ensuring that we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your PII or dealings.
Use of Non-PII
Company uses non-PII information it collects (including information that was fully anonymized with inability to be associated or attributed to an individual person), for the following purposes:
We retain this information for as long as necessary to fulfil our business and/or operational purposes or comply with a legal or regulatory requirement. We may also choose to anonymize parts of your PII so that it can no longer be identifiable or attributable to any unique device or person if we want to keep it for longer periods of time than the retention periods set forth above.
Additional Sharing of PII with Third Parties.
Except as described above, we may share your information with the following categories of third parties, for the respective purposes:
Transferring Personal Information From and Outside of the European Union
We will take appropriate steps to ensure that transfers of your PII are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end, if we as the data controller share your information with our corporate affiliates or third party service providers outside the EEA, we have - prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. We will provide further information on the means to ensure an adequate level of data protection on request.
Certain Software & Services may include content which may be in the form of apps, buttons, gadgets, advertisements, websites, products and services (including search services and advertisements) provided to you by third parties (collectively, "Third Party Content and Services"). The use of such Third Party Content and Services is subject to their privacy policies. In order to clarify, we do not review, approve, monitor, endorse, warrant, or make any representations with respect to such Third Party Content and Services and your access to any Third Party Content and Services is at your own risk. We are not responsible for the information contained and/or made available through, the practices of, or your use or inability to use such Third Party Content and Services. You expressly relieve us from any and all liability arising from your use of such Third Party Content and Services. We recommended that you read the terms, conditions and privacy policies of such Third Party Content and Services before using or accessing any of them.
Cookies and Other Technologies.
As indicated above, the Software & Services collects or allows third parties to collect, through blocks of code called “pixels” or “web beacons”, certain information about you and send it to our servers and to our partners (either directly or indirectly). We or our partners, may package all or part of this information into small text files called Cookies and send the Cookie to your computer. As an example, Cookies may store search queries made through the Software & Services, the web pages you accessed, your interaction with advertisements presented to you via the Software & Services, features you used, your session duration and your configurations and preferences of the Software & Services. You can learn more about cookies on the Internet Advertising Bureau’s website: http://www.allaboutcookies.org.
Most browsers are initially set up to accept Cookies but you can reset your browser to refuse all Cookies or to indicate when a Cookie is sent. However, some functions of the Software & Services may not function properly if your cookies are disabled.
To learn more about information collected by Verizon Media, please click here. To learn more about information collected by Microsoft, please click here. You can opt-out of Microsoft's personalized advertising services by following the instructions found here.
The Software & Services are not intended for minors in any jurisdiction and you hereby represent that you are not a minor according to you relevant jurisdiction. For example, users under the age of 13 in the United States and users under the age of 16 in the European Union are not permitted to use the Software & Services. We do not knowingly collect, use, share or disclose any personal information from minors. We reserve the right to request proof of age at any stage, so that we can verify that minors are not using the Software & Services.
We advise parents and guardians to regularly monitor their children's use of email and other online communications and activities. Control tools that create a safer online environment for children are available from third party online services and software providers. In the event that it comes to our knowledge that a minor is using the Software & Services, we will prohibit and block such a user from accessing the Software & Services and will make all efforts to promptly delete any PII with regard to such user, as applicable.
The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR or the CCPA):
If you are a California resident, the following rights may apply to you:
Exercising your Rights. You can exercise your rights by contacting us as provided under https://www.searchmomentum.net/ccpa. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
How we Protect your Information.
Do Not Track.
Do Not Track is a privacy preference that can be configured in certain web browsers (the "DNT Feature"); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Company does not currently respond or recognize DNT Feature signals.
If you have any complaints on our processing of your PII or if you believe that we have breached our own privacy policies or applicable law, we encourage you to contact us. However, please note that applicable EU data protection laws provide you with a right to lodge a complaint with the competent supervisory authority as well.
How to Contact Company.
Attention: General Counsel
26 HaRokmim Street, Azrieli Center 1
Building A, 4th Floor
Last updated: July 11, 2021