Spot.IM Ltd. and its affiliates (the “Spot.IM“, “we” or “us“) respect the privacy of the users of our online social network platform (the “Platform“), our website at: www.spot.im and/or our mobile application (the “Site” and “App“, respectively), and are committed to protect the personal information that users share with us in connection with the use of our Platform, Site and/or App, including via third party websites, blogs or other products or services which have integrated, embedded and/or otherwise use the Platform (“User Sites“, and collectively – the “Service“).
Spot.IM is dedicated to providing internet users the highest level of transparency and control over the use of their data in online advertising. Spot.IM adheres to the Self-Regulatory Principles set forth by the European Interactive Digital Advertising Alliance (EDAA). Spot.IM also adheres to the Interactive Advertising Bureau’s (IAB) Europe Online Behavioural Advertising Framework. To update your AdChoices Opt Out settings, select your region here.
We may collect two types of data and information from our Users:
1. The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Service (“Non-personal Information“). We are not aware of the identity of the User from which the Non-personal Information was collected.
Non-personal Information which is being collected consists of log data, technical information and aggregated usage information, and may contain, among other things, device settings, hardware information, device approximate location, mobile operator or internet service provider information, time zone, the activity of the User on the Service, User’s ‘click-stream’ and activity on the Service, including with respect to User Sites and/or Third Party Sites, de-identified Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks and your links’ interaction on the Service, domain names, landing pages, pages viewed, type of operating system, language and keyboard settings, etc.
2. The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual, or may be of private or sensitive nature (“Personal Information“).
Personal Information which is being gathered may consist of the following:
○ In the event that a User registers to the Service through his/her existing third-party Social Network Account (as defined under the Terms, namely the User’s Facebook, Twitter, LinkedIn or Google+ account, or other approved social platforms or networks), then such third-party social network may provide us with certain information about such User, as is stored in and/or made available by the User through his/her Social Network Account. For example, such information may consist, as applicable and/or made available by the User, of the User’s name, public profile picture URL address, Social Network Account User ID, e-mail address, date of birth, gender, occupation or work information, education and other information which the User made public. This Personal Information is automatically provided and stored by Spot.IM when registration to the Service is conducted via the User’s Social Network Account. We may also collect certain device identifiers, such as the registered user’s IP address.
○ In the event that a User registers to the Service through the registration form available on the Service, such User will be required to provide certain information such as his/her full-name, e-mail address, a User Account login password, profile picture and description; and/or
○ Any Personal Information provided voluntarily by the User via its use of the Service, user generated content provided through use of the Service, and/or other actions performed by the User in connection with the Service.
○ In the event a user communicates with us, we collect the Personal Information the user provided us with (such as correspondence and inquiries).
For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
There are four main methods we use:
In other words, when you are using the Service, including when you use the Service through any User Sites, we are aware of it and may gather, collect and automatically record the information relating to such usage, either independently or through the help of third-party services as detailed below. This information includes information about the websites and apps you visit, the comments you submit or upload through our Service, as well as information the developer or publisher of the website or app provides to us.
For example, we collect Personal Information which you voluntarily provide when you contact us directly, such as information you submit via your profile page.
(for example when you send us an email with a comment or feedback) we collect the Personal Information you provided us with.
4. We also collect information (including Personal Information) about you from third parties, for example our business partners, for marketing purposes and to deliver products or services you request.
We store the Personal Information either independently or through the help of our authorized third-party service providers as detailed below.
We collect Personal Information for the following purposes:
We will use and disclose your information (including your Personal Information) in order to provide and operate the Service, including for user authentication and identity verification purposes, as well as to enable us to provide our Users with a better and personalized user experience, with more relevant content and marketing materials; For example, we can suggest content that you might like based on your activity on our Service.
We will use and disclose your information (including your Personal Information) to investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate any fraud, security or technical issues, or respond to a government request. We also reserve the right to disclose any information in case we believe, in good faith, that such disclosure is appropriate or necessary in order to enforce our policies, take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, protect the security or integrity of the Service and our servers and protect the rights and property of Spot.IM, its users and/or others.
Our partners also use your information for behavioural advertising purposes, as detailed below.
If you registered with our Service we may send you promotional material, either concerning the Service or our partners’ marketing products, which we believe may interest you. You may choose not to receive our promotional or marketing emails (all or any part thereof) 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;
We will use and disclose your information to further develop, customize and improve the Service based on Users common preferences and uses.
We will use and disclose your information for statistical and research purposes, as well as to create and provide our business partners and affiliates with aggregated statistical data.
We use the information that we have to communicate with you – for example, we will use your contact details to respond to your queries or feedback, and to provide you with technical assistance and support.
Through our Service (including websites and apps that deploy our Service), we may provide advertisements that are tailored to you, for example ads that are based on your recent browsing behavior across different websites, browsers, or devices.
Spot.IM supports initiatives of greater transparency and control for users, and offers the following options for controlling the interest-based content and ads you receive.
If you reside in the EU and do not want to receive interest-based ads displayed by Spot.IM, you can disable the display of such ads by visiting the EDAA consumer choice page at www.youronlinechoices.eu.
You may also use the NAI opt out tool, which will allow you to opt out of seeing targeted ads from other NAI-approved member companies, and for mobile opt outs, the NAI provides instructions to engage system-level opt outs in Android, iOS, and Windows Phone environments.
Please note that opting out will not prevent you from seeing ads sourced from us on our Service or on other websites, but it will affect the types of ads that you will see. These ads will no longer be tailored to your interests and instead will be chosen based on the particular website that you are viewing (i.e. contextually based ads). Because our tracking mechanisms operate at the device and browser level, to fully opt-out across devices, you will need to do so on each device and browser individually. Also, if your browsers are configured to reject cookies when you visit the EDAA consumer choice page, your-opt out may not be effective.
We work with third party companies, who integrate our Service on the User Sites, as well as other third parties who help us provide and improve our Service or who use advertising or related products.
Spot.IM may share, transfer and disclose to our business partners any Non-Personal and Personal Information, in order maintain and improve our Service. This includes the operators or owners of User Sites and other third party partners that embed or deploy our Service on their respective websites, mobiles apps or other digital media.
Spot.IM may share Non-Personal and Personal Information in any manner required and permitted for such information, as well as (i) with our third party business partners for use in advertising targeting (e.g. through ad networks or servers); (ii) for the purposes described in the section above.
Please note that any information you voluntarily make available through the use of the Service, including your Personal Information (including your profile picture, your email address, you comments and posts, and any other content you make public through the use of the Service), is available to the public.
For avoidance of doubt, Spot.IM may transfer and disclose to third parties or otherwise use Non-personal Information at its sole discretion.
If you reside in the EU, you may request to:
1. Receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with certain supplementary information.
2. Receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your Personal Information that is in our control.
4. Request erasure of your Personal Information.
5. Object to the processing of Personal Information by us.
6. Request to restrict processing of your Personal Information by us.
7. Lodge a complaint with a supervisory authority.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you have any general questions about the Personal Information we collect and the ways we use it, please contact us at firstname.lastname@example.org.
We will retain your Personal Information for as long as necessary to provide our services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
To use the Service, you must be at least over the age of thirteen (13), unless the data protection laws in the country where you reside stipulate a higher age, in which event you must be at least over that age (“Age of Majority“).
Spot.IM does not knowingly collect Personal Information from children under the Age of Majority and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the Age of Majority are not using the Service. In the event that it comes to our knowledge that a person under the Age of Majority is using the Service, we will prohibit and block such User from accessing the Service and will make all efforts to promptly delete any Personal Information stored with us with regard to such User.
We take a great care in implementing and maintaining the security of the Service, and the User’s Personal Information. The Personal Information is hosted on Amazon Web Services, which provides advanced security features. Spot.IM employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information.
However, we do not and cannot guarantee that unauthorized access will never occur.
While using the Service you may encounter links to third party Content, User Sites and/or Third Party Sites, including through user generated content posted through the Service (collectively, “Third Party Services“).
When you visit or access our Service (including when you interact or engage with our Embedded Items), we authorize third parties to use web beacons, cookies, pixel tags, scripts, tags and other technologies (“Tracking Technologies“).
You may also contact at the following address:
Attn: Data Protection Officer
Yigal Alon 94, Tel Aviv, Israel, 6789156.