Cyfluencer Privacy Policy

This privacy policy ("Privacy Policy") outlines Wadi Digital Ltd.'s ("Wadi Digital," "we," "our," or "us") practices with respect to its collection, usage, and processing of information of those individuals who:

access or visit our website ("Visitors") available at: www.cyfluencer.com;
use and sign up for our Cyfluencer platform ("Platform") to either publish its content or blog posts ("Vendor Content" and"Vendor(s)," respectively) or to access and repost Vendor Content on their social media account ("Influencer(s)"). Vendor and Influencers shall be referred to collectively herein as "Partner(s)"; and
click on the Vendor Content that is displayed by the Influencers ("Viewers").

The website and the Platform shall be referred to collectively herein as the "Services". Additionally, Visitors, Partners and Viewers shall be collectively referred to herein as "you" or "your".

This Privacy Policy is an integral part of our Influencer Terms and Conditions and our Vendor Terms and Conditions (as applicable) (each the, "Terms") each of which shall include additional information and conditions regarding our Services. Any definitions that are used herein and not defined herein shall have the meaning ascribed to them in the Terms

We have included information below regarding which types of data are collected and how we process and use your data. However, before we get into that, we would like to explain the lawful basis upon which we collect, process and use your data (as further explained in the table below):

If you are a Partner, we will process your Personal Data (as such term is defined below) in order to perform our contract with you;
If we have a legitimate interest in processing Personal Data, such as for direct marketing or for security and verification purposes, when you access our website or as part of our Services; or
We will also process your Personal Data where you have provided us with your consent to do so if and as required under applicable law.

For the purposes of the European Union General Data Protection Regulation ("GDPR"), we are considered the Controller (as such term is defined under the GDPR) of the Personal Data we collect from our Visitors and Partners and considered the Processor (as such term is defined under the GDPR) of the Personal Data that we process from the Viewers.

If you are a resident of California, the California Consumer Privacy Act ("CCPA") may apply to you. Please review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA.

INFORMATION WE COLLECT

We may collect two types of data from you, depending on your interaction with us.

Non-Personal Data: The first type of data is non-identifiable, anonymous and aggregated data that is mainly technical data transmitted by your device and via your use of the Services. ("Non-Personal Data"). We are not aware of the identity of the individual who we collected the Non-Personal Data from.
Personal Data: The second type of data is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Data").

For the avoidance of doubt, any Non-Personal Data that is connected or linked to any Personal Data shall be considered Personal Data for as long as such connection or linkage exists. Furthermore, you are not required by law to provide us with any information and may choose to avoid providing us with certain Personal Data.

Information we collect from Visitors:

Type of Personal Data	Purpose of Processing and Lawful Basis
Contact Details In the event you contact us for support or other inquiries, either through the online form available on the website, by sending us an email or by any other means of communications that we make available to you, you may be requested to provide us with your full name and email address.	We will process this information subject to our legitimate interest and use it solely for the purpose of contacting you, responding to your inquiries and providing you with the support or information that you requested. We may process the contents of our correspondence with you in order to improve our customer service and in order to resolve any disputes with you (if applicable).
Newsletter If you voluntarily subscribe to our newsletter, you will be asked to provide us with your full name and email address. You can unsubscribe at any time by using the unsubscribe option within the body of the applicable email correspondence or by contacting us via email.	We use this information, based on your consent, solely in order to provide you with the content that you requested to receive. We use Postmark App for the purpose of managing our direct marketing activities. Postmark App's privacy policy can be found here: https://wildbit.com/privacy-policy.
Online Identifiers and Technical Non-Personal Data When you access our website or use our Services, we may, either directly or indirectly (through our third-party service providers) collect your IP address. We may collect technical Non-Personal Data from you when you access our website or use our Services as well, such as, your language preference, your "click stream" and the actions you took when you visited our website or used our Services.	In the event required under applicable law, we will obtain your consent to gather such information, for example, when we collect this information via cookies (as further explained below). Please note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address. Your IP address may be collected by our third-party analytic partners that offer ways to opt-out of such collection, all as explained below.

Type of Personal Data

Purpose of Processing and Lawful Basis

Contact Details

In the event you contact us for support or other inquiries, either through the online form available on the website, by sending us an email or by any other means of communications that we make available to you, you may be requested to provide us with your full name and email address.

We will process this information subject to our legitimate interest and use it solely for the purpose of contacting you, responding to your inquiries and providing you with the support or information that you requested.

We may process the contents of our correspondence with you in order to improve our customer service and in order to resolve any disputes with you (if applicable).

Newsletter

If you voluntarily subscribe to our newsletter, you will be asked to provide us with your full name and email address. You can unsubscribe at any time by using the unsubscribe option within the body of the applicable email correspondence or by contacting us via email.

We use this information, based on your consent, solely in order to provide you with the content that you requested to receive.

We use Postmark App for the purpose of managing our direct marketing activities. Postmark App's privacy policy can be found here: https://wildbit.com/privacy-policy.

Online Identifiers and Technical Non-Personal Data

When you access our website or use our Services, we may, either directly or indirectly (through our third-party service providers) collect your IP address.

We may collect technical Non-Personal Data from you when you access our website or use our Services as well, such as, your language preference, your "click stream" and the actions you took when you visited our website or used our Services.

In the event required under applicable law, we will obtain your consent to gather such information, for example, when we collect this information via cookies (as further explained below).

Please note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address. Your IP address may be collected by our third-party analytic partners that offer ways to opt-out of such collection, all as explained below.

In addition to the Personal Data included in the Visitors table above, if you are our Partner we will also process the Personal Data included in the Partners table below.

Information we collect from Partners:

Type of Personal Data	Purpose of Processing and Lawful Basis
Registration When you register for our Services via our website or via social media (i.e., Facebook, Twitter and LinkedIn), you may need to provide us with your full name, company name and the general geographical location (i.e., country level) of your company (if you are a Vendor), job title, email address and/or social media account details at the time of registration. If you are an Influencer, you will need to provide us certain information regarding your social media account whether or not you choose to register for our Services via such social media account for example, the name of the social media platform, number of followers, and a link to your social media account. We will also have access to publically posted profile information from your social media account.	In addition, we may process your Personal Data for our legitimate interests, for example, to send you marketing and promotional messages and offers related to our Services. You are able to unsubscribe from receiving such correspondence from us by clicking on the designated link in the applicable message that we will send you or by contacting us at: privacy@cyfluencer.com. Please note that if you choose to unsubscribe from direct marketing, we may still retain your contact details and send you relevant service-related information such as invoices and service rates.
Payment Information: As part of the Services you may be required to provide us with your payment details (including your PayPal UID, credit card information or bank account information). The payment details may be processed by us or our third party service providers	This information will be processed for the purpose of performing our contract with you and will enable you to use our Services. We use third party payment processors which may include PayPal. Consequently, any transactions that are processed by these third party payment processors will be governed by their privacy policies and terms which we recommend that you review. You can find PayPal’s privacy policy here.

Type of Personal Data

Purpose of Processing and Lawful Basis

Registration

When you register for our Services via our website or via social media (i.e., Facebook, Twitter and LinkedIn), you may need to provide us with your full name, company name and the general geographical location (i.e., country level) of your company (if you are a Vendor), job title, email address and/or social media account details at the time of registration. If you are an Influencer, you will need to provide us certain information regarding your social media account whether or not you choose to register for our Services via such social media account for example, the name of the social media platform, number of followers, and a link to your social media account. We will also have access to publically posted profile information from your social media account.

In addition, we may process your Personal Data for our legitimate interests, for example, to send you marketing and promotional messages and offers related to our Services. You are able to unsubscribe from receiving such correspondence from us by clicking on the designated link in the applicable message that we will send you or by contacting us at: privacy@cyfluencer.com.

Please note that if you choose to unsubscribe from direct marketing, we may still retain your contact details and send you relevant service-related information such as invoices and service rates.

Payment Information:

As part of the Services you may be required to provide us with your payment details (including your PayPal UID, credit card information or bank account information). The payment details may be processed by us or our third party service providers

This information will be processed for the purpose of performing our contract with you and will enable you to use our Services.

We use third party payment processors which may include PayPal. Consequently, any transactions that are processed by these third party payment processors will be governed by their privacy policies and terms which we recommend that you review. You can find PayPal’s privacy policy here.

Information we collect from Viewers:

Type of Personal Data	Purpose of Processing
IP Address, Geographical Location, and Technical Non-Personal Data. We will process your IP address when you click on any of the Vendor Content that is posted on an Influencer's social media account. Additionally, we will process some of your technical Non-Personal Data including the type of operating system you use, type of browser you use, the time and date you accessed the Vendor Content, the type of device that you use, as well as your approximate geographical location.	We will use this data in order to operate, provide, maintain, protect and manage our Services. As explained above, we are considered the Processor of this information and our Partners are considered the Controller. This data will be processed under our Partners legitimate interests to perform research, and conduct associated analytical and statistical activities, detect fraud, security or technical issues in connection with the Services and calculate payments for and to our Partners. Please note that, we do not attempt to analyze or determine your identity based on such information. Your IP address may be collected by our third-party analytic partners that offer ways to opt-out of such collection, all as explained below.

Type of Personal Data

Purpose of Processing

IP Address, Geographical Location, and Technical Non-Personal Data.

We will process your IP address when you click on any of the Vendor Content that is posted on an Influencer's social media account. Additionally, we will process some of your technical Non-Personal Data including the type of operating system you use, type of browser you use, the time and date you accessed the Vendor Content, the type of device that you use, as well as your approximate geographical location.

We will use this data in order to operate, provide, maintain, protect and manage our Services. As explained above, we are considered the Processor of this information and our Partners are considered the Controller. This data will be processed under our Partners legitimate interests to perform research, and conduct associated analytical and statistical activities, detect fraud, security or technical issues in connection with the Services and calculate payments for and to our Partners. Please note that, we do not attempt to analyze or determine your identity based on such information. Your IP address may be collected by our third-party analytic partners that offer ways to opt-out of such collection, all as explained below.

HOW WE COLLECT DATA

Depending on the nature of your interaction with us, we may collect information from you in one or both of the following ways

Automatically – we may use cookies (as explained below) or similar tracking technologies to automatically collect some information.
Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as via communications with us, when you subscribe for our newsletter or when you register for our Services, all as explained in this Privacy Policy.

SHARING INFORMATION WITH THIRD PARTIES

Wadi Digital will not share any Personal Data it collects with any third party, other than under the following circumstances:

Compelled Disclosures - To satisfy any applicable law, regulation, legal process, subpoena or governmental request;
Enforcement of our Rights - To enforce this Privacy Policy and the terms of our agreements (including the Terms), including the investigation of potential violations thereof;
Security Detections - To detect, prevent, or otherwise address fraud, security or technical issues;
Business Transfers and Affiliated Companies - When it is undergoing any change in control, including by means of a merger, acquisition or purchase of all or substantially all of its assets or with our parent company, any subsidiaries, joint ventures, or other companies under common control with Wadi Digital solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of any of the corporate transactions listed herein;
Service Providers - To collect, hold or manage your Personal Data through our authorized third-party service providers, as reasonable for our business purposes;
Explicit Consent - If you provide us with your explicit approval to share your information prior to the disclosure.

COOKIES POLICY AND TRACKING TECHNOLOGIES

We or our third-party service providers may use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with our Services.

A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.

The third-party cookies used on our website are as follows:

Cookie	Purpose	Privacy Policy
Google Analytics	Analytical, Measurement & Performance	www.google.com/policies/privacy/partners https://policies.google.com/technologies/managing?hl=en
Google Ads	Targeting & Advertising	https://tools.google.com/dlpage/gaoptout For additional information regarding our use of Google products, click here.
Facebook	Analytical, Measurement & Performance and Targeting & Advertising	https://www.facebook.com/policies/cookies/
LinkedIn	Analytical, Measurement & Performance and Targeting & Advertising	https://www.facebook.com/policy.php https://www.facebook.com/help/search/?q=opt%20out%20
Twitter	Analytical, Measurement & Performance and Targeting & Advertising	https://twitter.com/en/privacy
Reddit	Targeting & Advertising	https://www.redditinc.com/policies/privacy-policy
Bing Ads	Targeting & Advertising	https://privacy.microsoft.com/en-us/PrivacyStatement
HubSpot	Analytical, Measurement & Performance and Operation & Functionality. This category of cookies either cannot be disabled, or if disabled, certain features of the website may not work	https://legal.hubspot.com/privacy-policy?_ga=2.48898406.1547561739.1580054069-1042704558.1573974857
IPQualityScore	Analytical, Measurement & Performance and Operation & Functionality	https://www.ipqualityscore.com/privacy-policy

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited.

Please see the following links for more information with respect to how you can block or erase cookies via your particular browser: Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera.

DATA RETENTION

We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual requests to opt-out of such collection, subject to applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.

USER RIGHTS

Depending on your jurisdiction, data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we process (please review our User Rights Policy for more information regarding the rights you may have under the relevant data protection and privacy laws in your jurisdiction).

If you wish to exercise any or all of the above rights, please fill out the Data Subject Request Form ("DSR") available here, and send it to our privacy team at: privacy@cyfluencer.com.

If we are unable to provide you with the information that you asked for, we will endeavor to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.

SECURITY

We take great care in implementing and maintaining the security of your information. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any of such. We have implemented technical, physical and administrative security measures to protect your Personal Data, including without limitation by using industry standard encryption. In addition, we limit access to your Personal Data on our servers. The data collected by us is stored mainly on Digital Ocean's data servers in Frankfurt, Germany. Please visit the following link for more information regarding the data security provided by Digital Ocean.

Please contact us at privacy@cyfluencer.com if you believe that your privacy was treated in a way that was not in accordance with this Privacy Policy. In the event of a security incident in which we discover that your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if we are required to do so, subject to applicable laws).

DATA TRANSFER

We may store or process your Personal Data in the EU, the United States or in other countries. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our website. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data that was collected within the European Economic Area ("EEA") is transferred outside the EEA, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer

PROTECTING CHILDREN

The website and our Services are not intended for use by individuals who are under the age of eighteen (18). Therefore, Wadi Digital does not intend and does not knowingly collect any Personal Data directly from individuals who are considered to be children in their jurisdictions (i.e., under the age of sixteen (16) or as otherwise defined under applicable law in such jurisdiction), and does not wish to do so. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardian. If we obtain actual knowledge that a Visitor, Partner or Viewer is considered a child under applicable law, we will take steps to immediately delete his or her Personal Data. We request that such individuals do not provide Personal Data through our website or the Services. Please contact us at: privacy@cyfluencer.com. if you become aware or have any reason to believe that a child has shared any Personal Data with us.

CHANGES TO THIS PRIVACY POLICY

Wadi Digital reserves the right to amend this Privacy Policy at any time. As such we recommend that you re-visit this page frequently and review the Privacy Policy for any changes that we may have made. In the event that we made any substantial changes to this Privacy Policy, we will make reasonable efforts to provide you with notification with respect to such changes, if we are required to do so by applicable law. The changes to this Privacy Policy will go into effect as of the date listed in the “Last Amended” heading located at the top of this Privacy Policy.

CONTACT US

Please contact us if you have any questions (or comments) concerning this Privacy Policy, as follows:

By email: privacy@cyfluencer.com.
By mail: Wadi Digital Ltd. Gush Chalav 24/1 Pardes Hannah-Karkur, Israel