Privacy Policy

This privacy statement (“Privacy Policy”) explains the information, collection and use policies of [[COMPANY_NAME]] and any of its affiliated companies ("Company", “we” or “us”) with respect to the websites, services, products, technology, software and/or software components (collectively, the "Software & Services")of Company that you install, use, access or interact with ("use"), but excludes software and/or services that have separate privacy policies that do not incorporate this privacy policy.

We believe strongly in protecting the privacy of information entrusted to us. We acknowledge that you may have privacy and security concerns with respect to the information we collect, use, and disclose to third parties for the purpose of allowing us to offer and provide our Software & Services, so we have provided this Privacy Policy to explain, in as clear and plain language as possible, how we collect and use information. You will also find an explanation of certain rights you have (see the “Your Rights” section) in respect of your Personal Information.

Please read this Privacy Policy carefully, before using our Website, so you can fully understand our practices in relation to Personal Information, before we begin processing your information.

This Privacy Policy provides you with information about:

Information Company Collects and Receives.

When you Use the Software & Services, we automatically collect and store the following types of information:

  • Technical Information. Certain technical information regarding your device, and your Use of the Software & Services and other third party software and applications installed on your device (the “Other Software”), including the device type and version number, the type, name and version of operating system and Other Software including, without limitation, their interactions with the Software & Services, ISP (Internet Service Provider), hardware version, location, Internet protocol (IP) address, anonymous user identifiers such as cookies and similar web technologies, device configuration, version of the Software & Services, and your configuration and settings of the device and the Software & Services, including language and time zone;
  • Usage Information. Certain usage related information regarding your use and interaction with your device, including the Software & Services and Other Software, such as when and how you Use the Software & Services and Other Software, how you use your internet browser and internet search related applications, your language settings, the web pages you visit, applications you use and the content you see, access and utilize on such web pages and applications; for example, offerings and advertisements that you view, use and access, how you use them and your response to them (ie. clickstream data), how frequently you use them, your search queries and the non-precise location, time and date of your searches;
  • Support Related Information. If you communicate with us via our support section or via email, we may also collect your email address, name and any information voluntarily submitted by you in connection with such support (for example, your name, company name, and particular support query or request).

Except as described in this Privacy Policy, it is not our intention to personally identify or contact you through the collection of data described above (except for registration and user support purposes as set forth in this Privacy Policy). However, the data collected may include personally identifiable information or personal data as such terms are defined under applicable laws (“PII” or “Personal Information”) as a necessary part of using the Software & Services. For example, search terms that you enter when using search services as part of the Software & Services may include PII. In addition, IP address and other online identifiers such as cookies and similar web technologies are automatically transferred to us when you visit a publisher website that uses the Software & Services. Not being provided with such information, will affect our ability to provide you with certain elements of the Software & Services.


How Company Uses Your Information.

Use of PII

As stated above, we collect the following information from you:

  • IP Address;
  • Install-ID (for installations of specific software such as Browser Extensions);
  • Cookie Id;
  • URL Referrer;
  • Search terms; and
  • Support Related Information.

We consider this information to be PII, meaning that without this information, we would not reasonably be able to identify you. Company processes this information on the basis that it is a data controller of the PII. This is how we use this information:

  • To provide you with the search services and functionality, including providing you with the search results of our web search partners in response to your online search queries. We delete this data once our fraud and lifetime value assessment has been completed (as discussed in the next paragraphs). For this purpose, Company processes this information on the basis of a legitimate interest of an individual’s right to freedom of expression, including the freedom to hold opinions and to receive and impart information and ideas.

    We will share search term and your IP address with Microsoft, our search partner who provides you with certain aspects of the search services and functionality, including the results of your search queries. 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.

  • To detect and prevent fraud on its Software & Services.

    Company needs the combination of IP Address, Cookie Id, Install-ID, URL and Search Term to conduct fraud detection on potentially fraudulent and illegal uses of the Software & Services. 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 which we discuss 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 PII.

  • To assess the lifetime value of a user.

    In our experience, business performance in search is measured over a 24 month period, including, the lifetime value of a users that use our Software & Services. For that purpose, Company retains the Cookie-ID and Install-ID and the number of search queries performed (but not the actual search query itself) performed by each ID for a period of 24 months from the initial collection. For this purpose, Company processes this information on the basis of a legitimate interest for its business operations and internal due diligence.

  • Customer Support.

    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 individual ID generated or collected by us, unless you ask as to. For this purpose, Company processes this information on the basis of a legitimate interest and performance of a contract with you.

    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 in case of disputes and other legitimate reasons described in the next section “Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request”.

  • 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 fulfill 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 for the following purposes:

  • To operate and update the Software & Services, including in connection with Software & Services provided to our business partners, and to provide you with existing and new functionality and features of the Software & Services.

  • to improve, fix and customize the Software & Services;

  • to monitor, analyze and optimize your use of the Software & Services, including analyzing seasonal and annual usage trends and providing certain technical and usage information to our business partners as part of the services we provide; and

  • to maintain and improve the quality and operation of the Software & Services, including, monitoring viewability of and interaction with advertisements, search results and other products and services provided by Company.

We retain this information for as long as necessary to fulfill our business and/or operational purposes or comply with a legal request. We may also choose to anonymize parts of your PII so that it can no longer be identifiable or attributable to any 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.

We may also share your information in the following events:

  • We may also share your information with our subsidiaries, affiliated and parent companies pursuant to the legitimate interest for the provision of the Software & Services to you but their use of such information must comply with this Privacy Policy.

  • In the event Company goes through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred;

With respect to sharing of your PII, we take appropriate measures to minimize the PII that we disclose to the third parties, and we require these third parties (i) to keep the data secured, and (ii) to use the data solely in compliance with this Privacy Policy. In any case other than the above, we will not share your PII with third parties without your prior consent.


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. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission) or EU - US Privacy Shield certification. We will provide further information on the means to ensure an adequate level of data protection on request.


Third-Party Content.

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.


Minors.

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.

If you are a parent or guardian who has discovered that your child has submitted his or her PII without your consent, please contact us as provided in this Privacy Policy and we will take the necessary steps to remove that information from our database.


Your Rights.

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):

GDPR Rights:

  • You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

  • You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;

  • You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;

  • You have the right to object, to or to request restriction, of the processing;

  • You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;

  • You have the right to object to profiling;

  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

  • You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

CCPA Rights:

  • You have the right to know what personal information is being collected about you in the twelve months preceding your request;

  • You have the right to request the erasure/deletion of your personal data (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;

  • You have the right to know whether your personal information is sold or disclosed and to whom in the twelve months preceding your request;

  • You have the right to say no to the sale of your personal information;

  • You have the right to equal service and price, even if you exercise your privacy rights;

  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

Exercising your Rights. You can exercise your rights by contacting us as provided under “Contact Us” below. 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.

We have implemented and will maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. Note that, although we take measures to secure the information we collect and reduce the risk of unwanted disclosure, we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer or device you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this 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.


Complaints.

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.


Changes to This Privacy Policy.

We may, from time to time, change this Privacy Policy. We encourage you to visit and review this Policy frequently to stay informed. Prior to any material change to this Privacy Policy, Company will present you with a detailed notification (e.g. a pop-up notification or other reasonable means) of such change including information on how you may uninstall the Software & Services (to the extent applicable). Other changes, including amendments made to the Policy to comply with legal requirements, will become effective immediately upon their initial posting. Company will also update the "Last updated” date at the end of this Privacy Policy. Your continued use of the Software & Services after any change takes effect, will indicate your acceptance of the amended Privacy Policy. If you do not agree with any of the amended terms, you agree that you shall cease any further use of the Software & Services.


How to Contact Company.

If you have any concerns or questions with respect to any matter covered by this Privacy Policy, you may contact us at: info@clientconnect-inc.com or at the following address:

ClientConnect Inc.

Attention: General Counsel

One World Trade Center, 77th Floor, Suite A,

New York, New York 10007, USA

Last updated: July 5, 2020