DiscoverTech Ltd. (“DiscoverTech“, “we“, “our” or “us“) develops and provides data-driven performance marketing solutions for the mobile advertising industry, which allow us to bid on, and engage with individuals on behalf of mobile advertisers (our “Customers”) to (“End Users”) who are most likely to become high-value users of their mobile applications, as further described on the DiscoverTech website –  discover-tech.io. 

We respect the privacy of visitors to our website (“Visitors”), our Customers and their End Users (as applicable – “you”), and are committed to making our practices regarding their Personal Data more transparent and fair. This Privacy Policy describes how we collect, store, use and disclose such personal data, and our role as “Data Controller” or “Data Processor” with respect to each of our data processing activities. 

Specifically, this Privacy Policy describes our practices regarding: 

• Data Collection
• Data Uses
• Data Location and Retention
• Data Sharing
• Cookies and Tracking Technologies
• Communications
• Data Security
• Data Subject Rights
• Children’s Privacy
• Data Controller/Processor
• Additional Notices

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services. 

You are not legally required to provide us with any Personal Data (defined below), but without it we may not be able to provide you with the full range of Services or with the best user experience when using our Services. To learn more about the choices available to you, please read Section ‎8 below. 

• Data Collection

We collect Personal Data regarding our Customers, as well as data regarding Visitors. Such data is typically collected and generated through the Visitor’s interaction with our Services, through automatic means, directly from such Visitor or Customer, or from other third parties. 

In addition, we collect Personal Data regarding End Users, as our systems consider and bid on the opportunity to engage with them and show them our Customers’ advertisements (“Bids”); and following successful Bids and engagements, as we monitor the performance of our Services on behalf of our Customers. 

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“): 

• Data automatically collected or generated: When you visit, interact with or use our Services, or when we engage in Bids (and following successful Bids and engagements with you), we may collect or generate certain technical data about you.

We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below). 

Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, unique advertising IDs (e.g. IDFA; you may reset such ID by following the instructions below), non-identifying data regarding a device (such as type, screen resolution), operating system, app version, mobile carrier, in-app events and various apps usage statistics, browser version, locale and language settings used, visit history, search keywords, activities and actions on the website, general End User location (city, country, zip code), date and time stamp, types of advertisements viewed and click data, the pixels installed on such device, and the activity (clicks and other interactions) of Visitors and Customers in connection with our Services. Such data does not enable us to learn a person’s true identity or contact details. We mainly use this data to gain a better understanding on how Visitors, Customers and End Users typically use and interact with our Services; how we could improve their user experience; to optimize our product; and to optimize the overall performance of our Services. 

Your iOS mobile device may provide a “Limit Ad Tracking” setting. On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you have opted out using this setting on a device and that information is passed to DiscoverTech, DiscoverTech will not use your information to target ads to you or place you in segments for future marketing.

• Data received from our Customers: Customers may provide us with Personal Data such as their first and last name, address and email (collectively, “Account Data“), as well as any other data they choose to provide when contacting us.

Customers may provide us additional Account Data such as their billing details, business needs and preferences. To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), we will not regard it as “Personal Data” and this Privacy Policy shall not apply to it. 

Customers may also provide us with Personal Data concerning their colleagues or employees, in order to register them to our Services. Such Data usually refers to first names/nicknames and work e-mails, however additional data may be provided at the Customer’s discretion. 

• Customer Data received from third parties: we may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or services provides, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.
• End User Data received from third parties: we receive Personal Data relating to End Users from Ad Exchange networks, DMPs, Customers and mobile app publishers who share their users’ data with us (whether directly or via the Ad Exchanges).
• Data Uses

We use Personal Data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing and advertising services, customer service and support operations, and protecting and securing our Visitors, Customers, End Users, ourselves and our Services. 

We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA). 

 

Specifically, we use Personal Data for the following purposes: 

• To facilitate, operate, and provide ourServices;
• To authenticate and verify the identity and eligibility of ourCustomers;
• To provide Visitors, Customers and End Users with assistance andsupport;
• To manage and deliver Bids and advertisements more effectively, including contextual,behavioraland interests-based advertising based on End User activity, preferences or other data available to us or to our business partners, including for re-targeting purposes; 
• To create audience related insights for optimizing adperformance;
• To further develop, customize and improve the Services, based on common or personal preferences, experiences anddifficulties;
• To contact our Visitors and Customers with general or personalized service-related messages (such as regarding billing) and promotional messages (such as newsletters, new features, etc.); and to facilitate, sponsor and offer certain events andpromotions;
• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibitedactivity;
• To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
• To comply with any applicable laws and regulations.
• Data Location & Retention

Data Location: Your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers (defined below) in the United States of America, and other jurisdictions as necessary for the proper delivery of our Services, or as may be required by law. 

DiscoverTech is headquartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents. 

While privacy laws may vary between jurisdictions, DiscoverTech and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction. 

Data Retention: We retain Personal Data of Visitors and prospective Customers for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services. 

We retain Personal Data of Customers as necessary for us to provide them with our Services, to comply with our legal and contractual obligations, and to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy. 

We retain Personal Data of End Users as necessary for continuously optimizing the display and performance of our Customers’ ads, and to gain further insights based on the aggregation of data available to us. 

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete or anonymize it for any reason and at any time, with or without notice to you. 

If you have any questions about our data retention policy, please contact us by email at privacy@discover-tech.io. 

• Data Sharing

Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing. 

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, e-mail distribution and monitoring services, and our business, legal and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes. 

One of our Service Providers in particular is Google, which provides a tool called “Google Analytics”, used by us to track and analyze the use of our Services, for internal purposes. To learn more about how Google uses data from our use of Google Analytics, we recommend you review Google’s policies located at: google.com/policies/privacy/partners. For additional information, please see Google Analytics’ opt-out web tool available at: https://tools.google.com/dlpage/gaoptout. 

Sharing End User Personal Data with or on behalf of our Customers: We may share the Personal Data of End Users in accordance with the reasonable instructions of our Customers, each acting as the “Data Controller” of such data, as we act as the “Data Processor” and process such End User data on their behalf. For example, based on a Customer’s instructions, we may share their End Users’ Personal Data with another service provider also processing such Personal Data on such Customer’s behalf. 

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of DiscoverTech, any of our Customers or Visitors, End Users, or any members of the general public. 

DiscoverTech Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group for the purposes described in this Privacy Policy. In addition, should DiscoverTech or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services. 

For the avoidance of doubt, DiscoverTech may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval. 

• Cookies and Tracking Technologies

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers, and other tracking technologies that help us provide, secure, and improve our Services, personalize your experience and monitor the performance of our activities and campaigns. 

A “cookie” is a small text file that is used, for example, to collect data about activity on our Services. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the Visitor, Customer or End User. We recommend the use of cookies for an optimal user experience of our Services.   

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. 

If you wish to prevent the use of your mobile device’s advertising ID (e.g. for interest-based advertising), you may change your device settings to reset such advertising ID or to opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the “Settings” or “Help” section in your browser menu). 

If you are an End User who lives in the USA, Canada or Europe, you can also opt-out from the collection of your data by our Customers who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.youronlinechoices.com (for European users). 

Please note that if you reset your advertising ID or opt-out of interest-based advertising, you may still see advertisements served by DiscoverTech, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in a certain app, or your language preferences. Please note that such actions may result in a less enjoyable user experience. 

• Communications

Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, etc. We may also send you notifications, messages, and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use. 

Notifications and Promotional Communications: We may send you notifications concerning messages and other updates in your account. We may also send you notifications about new features, offerings, events, and special opportunities or any other information we think our Visitors or Customers will find valuable. We may provide such notices through any of the contacts means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. 

If you do not wish to receive such promotional communications, you may notify DiscoverTech at any time by sending an email to privacy@discover-tech.io or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive. 

• Data Security

In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any Service Providers as described in Section 4 above. 

• Data Subject Rights

If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Privacy Act (CCPA) such as the right to request access to, and rectification or erasure of your Personal Data held with DiscoverTech, or to restrict or object to such Personal Data’s processing, or to port such Personal Data (each to the extent available to you under the laws which apply to you)– please contact us by email at privacy@discover-tech.io. 

Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above. 

If you are an End User, we suggest you turn to the relevant Customer, acting as the Controller of your Personal Data in this instance (see Section 10 below for more details). 

• Children’s Privacy

Our Services are not designed to attract children under the age of 13. We do not knowingly collect any personal information from children under the age of thirteen through the platform. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our privacy policy by instructing their children never to provide personal information to us without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@discover-tech.io, and we will make all efforts to delete that information from our databases

 

• Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR and CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, the “Business”) who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, the “Service Provider”), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply. 

DiscoverTech is the “Data Controller” of its Visitors’ and Customers’ Personal Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. 

Only to the extent that a Customer has submitted any Personal Data concerning its End Users, such data shall be processed by DiscoverTech on behalf, as its “Data Processor”, and may be shared with such Customer in accordance with this Privacy Policy and in accordance with their reasonable instructions and our agreements with them. Such Customer shall be deemed the “Data Controller” of its End Users’ Personal Data and DiscoverTech will process such Personal Data on this Customer’s behalf, as its “Data Processor”. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control). 

 

If you would like to make any requests or queries regarding Personal Data we process on our Customer’s behalf, please contact them directly. For example, if you wish to access, correct, or delete data processed by DiscoverTech on behalf of a Customer, please direct your request to the relevant Customer (who is the “Data Controller” of such data). Should we receive such requests directly, we may refer them to our Customer. 

• Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you. 

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services. 

Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your Personal Data, please contact us by email at privacy@discover-tech.io. 

 

Effective Date [       20/05/2020      ]