User Privacy Policy

ReigNN is committed to ensuring that you are fully informed as to how your information is collected through the Sites you visit, that are using our services, and how it will be used by us. The following policy describes such collection and usage.

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PRIVACY POLICY

This website is operated by a Publisher who has referred the visitors and users of its website to this privacy policy (the “Publisher”).

This Privacy Policy explains Reignn’s privacy practices for processing certain Personal Information on the Website, by collecting and analyzing your behavior within the Website in order to match you with the most suitable format and number of advertisements you will view while visiting the Website. We process Personal Information as described in this Policy.

We are committed to protecting your privacy and processing your Personal Data fairly and lawfully in compliance with applicable data protections laws. You can access our full Privacy Policy below to help you understand better how we collect and use Personal Data pertaining to each of the Users of the Tool. In it, we explain in more detail the types of Personal Data we collect through the Tool, how we collect it, what is legal basis of collection, what we may use it for, who we may share it with, what our retention periods are and what are your rights in relation such Personal Data we collect.

Within the Privacy Policy you will find some specific examples of why and how we use your Personal Data.

Read this policy and make sure you fully understand our practices in relation to your Personal Data collected through the Tool, before you access or use the Website.  If you read and fully understand this Privacy Policy, and remain opposed to our practices you must opt out from using the Tool through the preference tab on the Website or by changing the preferences on our Website here. If you choose to opt-out and/or change your consent regarding the use of our Tool or if you have further questions or concerns regarding the Tool and/or this Policy please contact us at: info@reignn.com.


FULL PRIVACY POLICY

ReigNN Platform Ltd. (“ReigNN”, “we”, “our” or “us”) provides this Privacy Policy, as will be updated from time to time (our “Policy” or “Privacy Policy”) to inform the visitors of the Website, who decide to use our Tool (“you” or “User”) of our policies and procedures regarding the collection, use and disclosure of information we receive when you use the Tool through the Website.

  1. DEFINITIONS:

Publisher”- the owner and operator of the Website. 

Personal Data” means individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, collected on the Website through the Tool.

Non Personal Data” means information that does not personally identify you and does not reveal your specific identity as an individual, such as anonymized information, collected on the Website through the Tool.

Visitor” or “User” or “you” means visitors  of the Website.

GDPR” means the General Data Protection Regulation (EU) 2016/679, as amended from time to time.

Services” means use of our Platform by Users.

Tool” means the collection and process of your behavior within the Website in order to match you with the most suitable format and number of advertisements you will view while visiting the Website.

Website” means the public website of the Publisher, from which you were referred to this Policy.

This Policy was originally written in English. If you are reading a translation and it conflicts with the English version, please note that the English version prevails.

  1. WHEN DOES THIS PRIVACY POLICY APPLY

This Privacy Policy applies to Personal Data about you that we collect, use or otherwise process regarding your relationship with the Publisher as a visitor of the Website, through your use of the Tool.

This Privacy Policy does not apply to any services offered on the Website that may have separate privacy policies that do not incorporate this Policy (and which we are not responsible for) and does not apply to personal information or other information collected through the Website which is unrelated to the use of the Tool (which has no connection to Reignn).

  1. THE TYPES OF PERSONAL DATA THAT WE COLLECT

PERSONAL DATA THAT YOU PROVIDE TO US

While browsing the Website, you will not be providing us Personal Data (through the Tool).

THE PERSONAL DATA THAT WE COLLECT OR GENERATE

If you browse the Website, we may collect Personal Information through the Tool. This includes (by way of a non-exhaustive list): your device ID, computer’s Internet Protocol address and your Geo location- including region and country, through the use of “cookies”. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies to enable certain features of the Website, to better understand how you interact with the Website and to monitor web traffic routing and aggregate usage of the Website. You may opt out from using cookies through the preference tab on the Website or by changing the preferences on our website by clicking here. If you choose to opt-out and/or change your consent regarding the use of cookies or if you have further questions or concerns regarding the cookies contact us at:  info@reignn.com.

You will also be assigned with a random User ID. When a User visits more than one site which uses the Tool, or revisits the Website, cookies may allow recognizing the User under its unique User ID and adjusting advertising content accordingly. You may opt out from using User ID through the preference tab on the Website or by changing the preferences on our website at by clicking here. If you choose to opt-out and/or change your consent regarding the use of User ID or if you have further questions or concerns regarding User ID contact us at: info@reignn.com.

In some Websites, the Tool also uses the User Agent in order to adjust advertising format and quantity. The decision to use this feature of the Tool is made by the Publisher - please refer to the Publisher’s terms and conditions and privacy policy to find out if this feature of the Tool is used. If this feature is used on the Website - You may opt out from using User Agent through the preference tab on the Website or by changing the preferences on our website by clicking here. If you choose to opt-out and/or change your consent regarding the use of User Agent or if you have further questions or concerns regarding User Agent contact us at: info@reignn.com.

We may use GIFs in order to collect information. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.

  1. NON PERSONAL DATA

In addition to the categories of Personal Data described above, we will also process further anonymized information and data that is not processed by reference to a specific individual. We may collect this Non-Personal Data through the Tool used on the Website in the following ways:

  1. Information that your browser sends (“Log Data”). This Log Data may include, but is not limited to, non-identifying information regarding the User’s device, operating system, internet browser type, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, the specific web page you were visiting within the Website, etc.
  2. We may use automated devices and applications to evaluate usage of our Service. We use these tools to help us improve the performance and user experience of the Tool. We may also engage third parties to track and analyze data or provide other services on our behalf. Such third parties may combine the information that we provide about you with other information that they have collected from other sources. This Policy does not cover such third parties’ use of the data and such use is governed by such third parties’ privacy policies.
  3. Other websites and applications may also place or read cookies on your computer’s browser. Please see below the Section “SHARING INFORMATION WITH OTHERS” below.
  1. HOW WE USE PERSONAL DATA

Personal Data is used for the following primary purposes (as may be updated from time to time): to (i) adjusting advertising content; (ii) monitor and analyze use of the Website and study and analyze the functionality of the Website; (iii) enforce our Terms of Use, policies and other contractual arrangements, to comply with court orders and warrants, and prevent misuse of the Website, and to take any action in any legal dispute and proceeding.; (iv)  disclose to third party vendors, service providers, contractors or agents who perform functions on our behalf with respect to the Website; (v) to create aggregated statistical data and other aggregated and/or inferred Non-Personal Data, which we or our business partners may use to provide and improve the Website; and (vi) as otherwise authorized by you.

  1. HOW WE USE NON PERSONAL DATA

We may use information that is Non Personal Data for the same purposes we use Personal Data (where applicable) and in addition in order to (i) compile anonymous or aggregate information, (ii) disclose to third party vendors, service providers, contractors or agents who perform tasks on our behalf in connection with the services provided through the Website and (iii) provide us with statistical data.

From time to time, we may use additional or alternative analytics services. We will provide a notice of these changes as an update to our Policy, see Section ‎16 - “CHANGES TO THE PRIVACY POLICY”.

We use the following types of “cookies” to collect information:  analytics cookies, session cookies, functionality cookies, authentication cookies, 'strictly necessary’ cookies and targeting or advertising cookies .A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies to enable certain features of the Website, to better understand how you interact with the Website and to monitor web traffic routing and aggregate usage of the Website. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Website.

  1. THE LEGAL BASIS FOR USE OF PERSONAL DATA

We will only process your Personal Data where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use your Personal Data. In almost all cases the legal basis will be:  

Because you consented to us using the Personal Data for a particular purpose.

More information on each legal basis is provided below.

More information on the basis of processing:

You consent to the processing of Personal Data for one or more specific purposes, for example: 1) to adjusting the number and format of ads you view on the publisher’s website 2) to adjusting advertising content in case the publisher you are visiting is working with us as a demand partner. You may withdraw your consent trough the Consent management platform on the Website or on our website available here.

It is hereby clarified that the legal bases detailed above are the legal bases for actions to process Personal Data, carried out by us in accordance with the GDPR. If processing of Personal Data is subject to other applicable laws, then the legal basis for processing Personal Data may differ according to those applicable laws. 

For more information, see Section “YOUR RIGHTS” below.

  1. SHARING INFORMATION WITH OTHERS

We do not sell, rent or lease your Personal Data. We may share your Personal Data with service providers and other third parties, if necessary to fulfil the purposes for collecting the information, such as cloud vendors, subcontractors providing us processing services, advertisement providers, etc., provided that any such third party will commit to protect your privacy as required under the applicable laws and this Policy.

Additionally, a merger, acquisition or any other structural change may require us to transfer your Personal Data to another entity, provided that the receiving entity will comply with this Policy.

  1. SHARING INFORMATION WITH AUTHORITIES

We may need to disclose Personal Data in response to lawful requests by public authorities or law enforcement officials, including meeting national security or law enforcement requirements. We cooperate with government and law enforcement officials to enforce and comply with the law.

  1. TRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store, process or maintain information in various sites worldwide, including through cloud based service providers worldwide. Where the GDPR applies and we transfer Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:

  1. the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data (Israel is an approved country);
  2. the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
  3. where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
  4. In other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.

You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described the Section “CONTACT US” below.

If you are located in a jurisdiction where transfer of your Personal Data to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer or the storage, processing or maintenance of the information in other jurisdictions by using the Website.

  1. YOUR RIGHTS

In all of the above cases in which we collect, use or store your Personal Information, you may have the following rights and, in most cases, you can exercise them free of charge.

At any time, you may contact us at: info@reignn.com and request to know what Personal Data we keep about you. We will make good-faith efforts to locate the data that you request to access.

Under your right of access, you may obtain confirmation from us of whether we are processing Personal Data related to you, receive a copy of that data, so that you could verify its accuracy and the lawfulness of its processing, request the correction, amendment or deletion of the data if it is inaccurate, incomplete, outdated or processed in violation of applicable law.

However, we may retain certain information as deemed required by us in accordance with applicable laws, or for legitimate business reasons, for the duration as required under applicable laws.

In addition, we may delete any Personal Data pursuant to our policies, as in effect from time to time.

  1. RESPONSE TO REQUESTS

When you ask us to exercise any of your rights under this Policy and the applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data related to others and to ask you questions to better understand the nature and scope of data that you request to access.

We may redact from the data which we will make available to you, any Personal Data related to others.

  1. DATA SECURITY

We take the safeguarding of the Personal and Non Personal Data very seriously, and use a variety of systems, applications and procedures to protect the information from loss, theft, damage or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict access to the information. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Website will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

We also regularly monitor our systems for possible vulnerabilities and attacks.

  1. DATA RETENTION

We retain different types of information for different periods, depending on the purposes for processing the data, our legitimate business purposes as well as pursuant to legal requirements under the applicable law. We may retain Personal Data for as long as necessary to support the collection and the use purposes under this Policy and for other legitimate business purposes, for example, for storing data, for documentation, for cyber-security management purposes, legal proceedings and tax issues. We may store aggregated Non Personal Data without time limit. In any case, as long as you use the Website, we will keep information about you, unless we are legally required to delete it, or if you exercise your rights to delete the information.

  1. OUR POLICY TOWARD CHILDREN

The Website is not meant to be used by or for persons under 18, as such, we do not knowingly collect Personal Data from minors younger than 18. Insofar as Personal Data may be collected based on your consent, the data subject must be above the age of 16 (or above the age of 13 if this is the legal requirement in your country). If these age requirements are not met, you are required to obtain the consent of the parent or guardian to provide and process information in accordance with this Policy; lacking such consent, please do not use the Website.

  1. CHANGES TO THIS PRIVACY POLICY

We may change the terms of this Privacy Policy from time to time by posting notice on the Website, with a seven (7) day advance notice. However, substantial changes will be effective thirty (30) days after the notice was initially posted. The Publisher shall contact you in order to receive your consent to such changes.

If we need to adapt the Policy to legal requirements, the amended Policy will become effective immediately or as required.

Your continued use of the Website with the Tool following such notice shall constitute your consent to any changes made and a waiver of any claim or demand in relation to such changes. If you do not agree to the new or different terms, you should not use and are free to discontinue using the Tool by clicking here.

  1. APPLICABLE LAW AND DISPUTE RESOLUTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Israel, without regard to its conflict of law provisions. 

The courts of the Tel Aviv – Jaffa district shall have exclusive jurisdiction in all disputes and proceedings arising from this Privacy Policy.

  1. CONTACT US

For further information about this Policy, please contact our privacy officer at info@reignn.com.

We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact us and we will make good-faith efforts to address your concerns. We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.

 Copyright © 2018, Reignn All rights reserved.

Last Updated: October 3, 2018

 

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