Last update: 15/01/2020 Version: 2.0
- What personal data (“PD”) and non-personal data (“NPD”) we collect from you, for what purposes we use it, how we protect it, and how we share it with third parties;
- How you can access and change your PD and how you can limit our sharing of it; and
- Your legal rights that you have with respect to your PD.
- General Information and Definitions 1
- Types and Purposes of PD and NPD that We Process 2
- Sharing Your PD and NPD with Third Parties 4
- Transfer of PD Outside Your Country 6
- Retaining and Destroying Your PD and NPD 6
- Your Rights Regarding Your PD 6
- Protecting the Privacy Rights of Third Parties 8
- Do Not Track Settings 8
- Links to Third-Party Websites 8
- Protecting Children’s Privacy 9
- Our Email Policy 9
- Our Security Policy 9
- Contact Us 10
1.1 About the Website. The Website allows you to create and access Japanese emoticons.
1.2 Our role as a data controller. The entity that is responsible for the processing of your PD though the Website is Algo Media LTD having an address at Hasaham 30, Petah tiqwa, 49517 Israel (“we”, “us”, and “our”). We act as a data controller with regard to your PD collected through the Website (e.g., when you register your user account, browse the Website, or communicate with us). In such instances, we are a data controller because we make decisions about the types of PD that should be collected from you and the purposes for which such PD should be used.
1.3 Applicable laws. We process PD in accordance with applicable data protection laws, including, but not limited to, the Israeli Protection of Privacy Law, the EU General Data Protection Regulation (“GDPR”), and the California Consumer Privacy Act (“CCPA”).
- “NPD”meansnon-personal data that does not allow us to identify you in any manner;
- (“PD”) means personal data, i.e., any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.
- “Visitor” is someone who merely browses our W A “member” is someone who has registered with us to use our services. The terms “user”, “you”, and “your” are collective identifiers that refer to either a visitor or a member.
- “Consent” means a freely given, specific, informed and unambiguous agreement to the processing of
- “Data controller” means the entity that determines the purposes and means of the processing of
- “Data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.
- “Processing” means the use of PD in any manner, including, but not limited to, collection, storage, erasure, transfer, and disclosure of personal data.
When you create a Japanese emoticon and upload it onto the Website, we collect your:
When you contact us by email or through the contact form, we collect your:
▪ To respond to your enquiries
▪ To provide you with the requested information
When you use the Website:
When you donate through the Website, we collect your:
2.2 NPD that we collect. When you use the Website, we automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our Website, if any, as well as the name of the website you’ll visit when you leave our Website.This information also includesyour Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our Website. We use all this NPD to (i) analyse trends among our users to help improve our Website, (ii) identify and fix errors, and (iii) develop additional features and services.
2.4 What Happens If You Don’t Give Us Your PD?If you do not provide us with the PD when requested, we may not be able to provide you with all our products and services. However, you can access and use some parts of our Website without giving us your PD.
2.5 Sensitive data. We do not intentionally collect special categories of personal data (‘sensitive data’), such as opinions about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about sexual orientation.
2.6 Your feedback. If you contact us, we may keep records of any questions, complaints or compliments made by you and the response, if any. Where possible, we will de-identify your PD. Please note that de-identified PD is also considered to be NPD.
2.7 Aggregated data. In case your NPD is combined with certain elements of your PD in a way that allows us to identify you, we will handle such aggregated data as PD. If your PD is de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered PD and we may use it for any legitimate business purpose.
3.1 Selling your PD and NPD. WE DO NOT SELL YOUR PD TO THIRD PARTIES FOR MARKETING OR OTHER PURPOSES. The term “sell” refers to selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your PD by us to another business or a third party for monetary or other valuable consideration. For data aggregation purposes, we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD.
3.2 Sharing PD with our data processors. If necessary for the purposes listed below, we will share your PD specified in section 2.1 with our third-party service providers we hire to provide services to us (“Our Processors”). Our Processors include, but are not limited to, payment processors, web analytics companies, advertising networks, help desk providers, accountants, law firms, auditors,and email service providers.The disclosure of your PD to Our Processors is limited to the situations when such data is required for the following purposes:
- Ensuring the proper operation of our Website;
- Ensuring the delivery of the services requested by you;
- Providing you with the requested information;
- Pursuing our legitimate business interests;
- Enforcing our rights, preventing fraud, and security purposes;
- Carrying out our contractual obligations;
- Law enforcement purposes; or
- If you provide your prior consent to such a disclosure.
|Hosting service provider||Media Temple||United states||https://mediatemple.net/|
|Business analytics service provider||Google Analytics||United States||https://analytics.google.com|
|Header bidding partner||Adapex||United States||https://adapex.io/|
|Email service provider||Sendgrid||United States||https://sendgrid.com|
|Donation (payment processing) service providers||PayPal||United States||https://www.paypal.com|
|Technical support service providers||IT Syndicate||IT Syndicate||HongKong|
|Our group of companies||Landocs Holdings Ltd, Ran Ventures Ltd, Komantra Holdings Ltd, Keeper Holdings Ltd|
|Software developing partners and business advisors||Independent contractors|
3.4 Legally required releases of PD.We may be legally required to disclose your PD if such disclosure is: (i) required by subpoena, law, or other legal process; (ii) necessary to assist law enforcement officials or government enforcement agencies; (iii) necessary to investigate violations of or otherwise enforce our legal terms; (iv) necessary to protect us from legal action or claims from third parties, including you and/or other users or members; or (v) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.
3.6 Disclosure of NPD. We may disclose your NPD and de-identified PD for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving the Website, responding to lawful requests from public authorities, or developing new products and services.
4.1 The PD that we collect from you may be stored, processed, and transferred between any of the countries in which we or Our Processors operate. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA.
4.2 Wherever we transfer, process or store your PD, we will take reasonable steps to protect it. For example, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your PD (e.g., the country in which the recipient is located is white-listed by the European Commission or the recipient is a Privacy-Shield certified entity) or we conclude an agreement with the respective third party that ensures such protection (e.g., a data processing agreement based on the Standard Contractual Clauses provided by the European Commission).
4.3 The EuropeanCommission has not found the United States and some other countries where we and our Processors are located to have an adequate level of protection of PD under Article 45 of the GDPR. We rely on derogations for specific situations as defined in Article 49 of the GDPR. We will use your PD to provide the goods, services, and/or information you request from us to perform a contract with you or to satisfy a legitimate interest of our company in a manner that does not outweigh your freedoms and rights.
5.1 Retention of PD. We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. We always make sure that we have a lawful basis for storing your PD. Your information may be retained in electronic form,paper form, or a combination of both. When your PD is no longer needed and there is no lawful basis for storing it, we will securely destroy, delete, or erase it.
5.3 Retention as required by law. Please note that, in some cases, we may be obliged by law to store PD for a certain period of time (e.g., we have to keep our accountancy records for the time period prescribed by law). In such cases, we will store PD for the time period stipulated by the applicable law and delete it as soon as the required retention period expires.
6.3 You rights.When using our Website and submitting PD to us, you may have certain rights under the GDPR, the CCPA, and other applicable laws. Depending on the legal basis for processing your PD, you may have some or all of the following rights:
- The right to be informed. You have the right to be informed about the PD we collect from you, and how we process it.
- The right of access. You have the right to get confirmation that your PD is being processed and have the ability to access your PD.
- The right to rectification.You have the right to have your PD corrected if it is inaccurate or incomplete.
- The right to erasure (right to be forgotten). You have the right to request the removal or deletion of your PD if there is no compelling reason for us to continue processing it.
- The right to data portability. You have the right to request and get your PD that you provided to us and use it for your own purposes. We will provide your PD to you in a machine-readable format (e.g., a .pdf file) within 30 days of your request.
- The right to restrict processing. You have a right to ‘block’ or restrict the processing of your PD. When your PD is restricted, we are permitted to store your PD, but not to process it further.
- The right to object.You have the right to object to us processing your PD for the following reasons:
- If the processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing (including profiling); and
- Processing for purposes of scientific/historical research and statistics.
- Automated individual decision-making and profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- Filing a complaint with authorities.You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the applicable laws. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.
6.5 How to launch a complaint? If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
If any postings you make on our Website contain information, including PD, about third parties, you must make sure you have the permission to include that information in your posting. While we are not legally liable for the actions of our users, we reserve the right to remove any postings about which we are notified, if such postings violate the privacy rights of others.
Some web browsers have settings that enable you to request that our Website not track your movement within our Website. Our Website does not obey such settings when transmitted to and detected by our Website. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.
OurWebsite is not designed for use by anyone under the age of 18. Thus, we do not knowingly collect PD from children under the age of 18. If you are a parent or guardian and believe that your child under the age of 18 is using our Website or submit any PD throughit, please contact us. Before we remove any PD from our systems, we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child under the age of 18 is accessing our Website, we will delete his/her PD within a reasonable period of time.
Normally, we do not send marketing messages or informational notices to you. However, if we decide to do so and you sign up to receive our newsletter or provide your consent, we will, from time to time, send you marketing messages, such as newsletters, brochures, promotions and advertisements, informing you about our new services or new features of the Website. You will be able to easily opt-out from receiving marketing messages by clicking on the “unsubscribe” link included in every email. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission.
12.1 We have built our Website using industry-standard security measures and authentication toolsto protect the security of your PD. We and Our Processors also maintain technical and physical safeguards to protect your PD.
12.2 We implement organisational and technical information security measures to protect your PD from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include strong passwords, DDOS mitigation, limited access to your PD by our staff, and anonymisation of PD (when possible).
12.3 When we collect your creditcard information through our Website, we will encrypt it before it travels over the Internet using industry-standard technology for conducting secure online transactions. Unfortunately,we cannot guarantee against the loss or misuse of your PD or secure data transmission over the Internet because of its nature.We use third-party billing services and have no control over these services.We use our commercially reasonable efforts to make sure your credit card number is kept strictly confidential by using only third-party billing services that use industry-standard encryption technology to protect your credit card number from unauthorised use.
12.4 We strongly urge you to protect any password you may have for our Website and to not share it with anyone. You should always log out of our Website when you finish using it, especially if you are sharing or using a computer in a public place.
12.5 Security breaches. Although we put our best efforts to protect your PD, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your PD caused by circumstances that are beyond our reasonable control. In case a PD breach occurs, we will immediately take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
13.3 Repurposing of PD.If at any time we decide to disclose or use your PD in a method different from that specified at the time it wascollected, we will provide advance notice by email (if we have it) and, if necessary seek your consent.
Company: Algo Media LTD
Address:Hasaham 30, Petahtiqwa, 49517 Israel
© Copyright notice – This document is protected under the Israeli and foreign copyrights. The copying, redistribution, use or publication by you without our consent is strictly prohibited.