Conversion People (“Conversion People”) comunderstands that protecting the privacy of those who visit its website, is of great importance. This is the reason why we are taking the necessary steps to ensure the privacy of those who visit our website (the “Site”). This Privacy Policy applies to the Site and supervises the way that information is gathered on the Site and the use that is made of such information. By using the Site, you are consenting to the conditions that appear in this policy.

Collecting information

Conversion People might collect personal identification details such as your email address, your name, your residential/work address or your phone number. In addition, Conversion People might collect anonymous demographical information which is not unique to you – such as your area code, age, gender, preferences and areas of interest. In addition, information regarding your computer hardware and software is gathered automatically. This information could contain your IP address, the type of browser, names of site/users, access times and references to other internet sites. This information will be used by Conversion People to activate services, to carry out quality control of the services and to provide general statistics relating to the use of the Site. Please bear in mind that to the extent that you provide personal identification information, or personal sensitive information of any kind through the public channels on the Site, this information could be collected and used by other people.

*Remark – Conversion People does not read private on-line communications. Conversion People strongly recommends that you review the privacy declarations of the sites to which connect from the Site, so that you will be able to see how these sites gather, use and involve other people, in your information. Conversion People may only collect information through Cookies.

Use of your personal data

Conversion People collects and uses your personal data for the purpose of running the Site and to provide services which you request. Conversion People also makes use of your identification details to bring to your notice other products and services which are available to you on the Site and its add-ons. Conversion People may also make contact with you through surveys in order to get your opinion about its existing services and about new or potential services which it may offer you in the future. Conversion People does not sell, hire or rent out its customer listings to any third parties. Conversion People may, from time to time, contact you on behalf of its external business partners regarding special offers which could be of interest to you. In that circumstance, the personal identification details which are unique to you (such as your email address, name, address, phone number, etc.) are not given to any third parties. In addition, the Conversion People Site may share information with reliable partners when obtaining their assistance with statistical analysis, contacting you by email or post, providing support to customers or arranging shipment. None of these third parties are allowed to use your personal identification details other than for the purpose of providing services for the Site and must respect the confidentiality of your details. Conversion People does not use or share sensitive identification information such as ethnicity, religion or political leanings without your specific consent. Conversion People protects information and carries out a follow-up of the sites and internet pages on the Site which our customers visit, in order to identify what services on the Site are the most popular. This information is used to send personalized content and advertising from the Site to customers whose activity suggests that they are interested in specific subjects. The Site will hand over your personal details without giving you notification, only if it is required to do so by a legal authority or when it genuinely believes that doing is necessary in order to: (a) to comply with the demands of the law or to cooperate with legal proceedings being conducted on the Site; (b) to protect and defend the rights and property of the Site; (c) to operate under circumstances of extreme emergency to protect the integrity and security of the Site’s users or of the general public. Conversion People will not use PII’s (Personal Identifiable Information) for targeting.

Using cookies

The Site uses “Cookies” to help you achieve a personally matched online experience. Cookies are text files located on your hard disc by the server. Cookies cannot be used to run software or to introduce viruses on to your computer. Cookies are adapted for you uniquely and can be activated only by the server that is operating the file on your computer. One of the main purposes of Cookies is to facilitate time-saving. The objective of Cookies is to tell the site server that you have revisited a particular internet page. For example, if you have personally verified pages on the Site or registered for the Conversion People Site or for its services, the Cookie helps the Site to retrieve personal data concerning other visits made there. This simplifies the process of documenting your personal data such as billing address and shipment address, etc. When you go back to that Site the information you provided previously can be collected and you will be able to make simple use of the features offered on the Site which you have personally authenticated. You have the choice of whether to accept or reject Cookies. Most computer browsers are programmed by default to automatically allow Cookies, but in general it is possible to change the browser option and refuse to accept cookies – if that is your preference. If you refuse to accept cookies, it is possible that you won’t be able to experience all the features and services offered you on the Site or on the other sites you visit.

Your personal data protection

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website. Please take a look at the “LAST UPDATED” date at the bottom of this Privacy Policy to see when it was last revised.

Mobile In-App

Opt-out instructions – Android – https://support.google.com/ads/answer/2662922?hl=en iOS – https://support.apple.com/en-us/HT202074

Contact us

The Site welcomes any comments you make about this Policy. If you believe that Conversion People is deviating from its Policy, please contact us at [email protected]– we will do everything is in our reasonable power and commercial capacity to attend to the problem immediately. Last updated: 4/08/2017

 

Publisher Data Processing Agreement

 

This Data Processing Agreement (the “Agreement“) is entered into by and between Conversion People, a corporation with an office at 7 Rival St., Tel Aviv, Israel (“Conversion People“) and its publishers (“Publisher”). The parties hereby agree to the following:

 

  • Introduction.
  1. Publisher is a controller of certain personal data that it wishes to share with Conversion People in connection with the MSA (as defined below).
  2. The parties have entered into this Agreement to ensure that, in sharing such personal data pursuant to the MSA, they both are in compliance with Privacy Laws and the fundamental data protection rights of the data subjects whose personal data will be processed.

 

  • Definitions.
  1. controller“, “processor“, “data subject“, “personal data“, “processing” (and “process“) and “special categories of personal data” shall have the meanings given in the applicable Privacy Laws;
  2. EU Data Protection Law” means (i) prior to May 25, 2018, the EU Data Protection Directive (Directive 95/46/EC); (ii) on and after May 25, 2018, the EU General Data Protection Regulation (Regulation 2016/679); (iii) the EU e-Privacy Directive (Directive 2002/58/EC); and (iv) any national data protection laws made under or pursuant to (i), (ii) or (iii).
  3. Privacy Laws” means all applicable federal, state and international laws, rules, regulations, self-regulatory guidelines and prevailing industry standards that govern the activities of Conversion People and Publisher under this Agreement.

 

  • Purpose of Processing.
  1. Conversion People and Publisher are parties to an existing master services agreement – supply dated as of May 16th, 2018 under which Publisher may send ad calls for its available inventory via Conversion People’s services for the purpose of receiving bids from Conversion People’s advertiser and agency clients (the “MSA”).  In connection with this purpose, Publisher will submit certain advertising inventory bid requests to Conversion People, and Conversion People acknowledges that such bid requests may contain data that qualify as personal data under Privacy Laws (such as IP addresses and similar unique device identifiers) (“Data“).  Publisher agrees to not pass any such Data unless it has received consent from the data subject pursuant to Privacy Laws.
  2. Conversion People shall process such Data for the purpose of assessing whether to submit bids for the advertising inventory made available by Publisher and/or as otherwise described in the MSA or otherwise agreed in writing by the parties (the “Permitted Purpose“). Upon Publisher’s request, Conversion People will restrict the processing of Data identified by Publisher.  Conversion People will process the Data in accordance with the requirements of Privacy Laws and Publisher will ensure that any instructions for the processing of Data will comply with the Privacy Laws.

 

  • Data Subjects. If Publisher, in its use or receipt of Conversion People’s services, does not have the ability to correct, amend, restrict, block or delete Data, Publisher will promptly notify Conversion People of such inability and Conversion People will use all reasonable efforts to facilitate such actions to the extent Conversion People is legally permitted and able to do so.

 

  • Relationship of the Parties. The parties acknowledge that Publisher is a controller of the Data it discloses to Conversion People, and that Conversion People will process the Data as a separate and independent controller strictly for the Permitted Purpose.  In no event will the parties process the Data jointly as joint controllers.

 

  • Compliance with Law. Each party shall be individually and separately responsible for complying with the obligations that apply to it as a controller under Privacy Laws.  Without limitation to the foregoing, each party shall maintain a publicly-accessible privacy policy on its website(s) that satisfies the transparency disclosure requirements of Privacy Laws.

 

  • Non-Disclosure. Conversion People will not disclose the Data to any third party without Publisher’s prior written consent except: (i) where necessary for the Permitted Purpose; (ii) as permitted or required pursuant to the MSA; or (iii) where required by applicable law.

 

  • Security. Conversion People shall implement appropriate technical and organizational measures to protect the Data from (i) accidental or unlawful destruction; and (ii) loss, alteration, unauthorized disclosure of, or access to, the Data (a “Security Incident“).  In the event that Conversion People suffers a confirmed Security Incident, it shall notify Publisher without undue delay and both parties shall cooperate in good faith to agree and take action upon such measures as may be necessary to mitigate or remedy the effects of the Security Incident.

 

  • Subcontracting. Conversion People may appoint third party processors to process Data for the Permitted Purpose, provided that such processors: (i) agree in writing to process Data in accordance with Conversion People’s documented instructions; (ii) implement appropriate technical and organizational security measures to protect the Data against a Security Incident; and (iii) otherwise provide sufficient guarantees that they will process the Data in a manner that will meet the requirements of Privacy Laws.  Conversion People accepts responsibility for any breach of this Agreement that is caused by an act, error or omission of a processor it has appointed.

 

International Transfers.  Where EU Data Protection Law applies, Conversion People shall not transfer any Data (nor permit any Data to be transferred) to a territory outside of the European Economic Area (“EEA“) unless it has taken such measures as are necessary to ensure the transfer is in compliance with EU Data Protection Law.  Such measures may include, without limitation, transferring the Data to a recipient in a country that the European Commission has decided provides adequate protection for personal data; to a recipient that has achieved binding corporate rules authorization in accordance with Privacy Laws; to a recipient in the United States that has certified compliance with the EU-US Privacy Shield framework; or to a recipient that has executed standard contractual clauses adopted or approved by the European Commission.

 

  • Cookie Consent. Conversion People uses cookies and similar tracking technologies (such as mobile device identifiers and digital fingerprinting) (“Cookies“) to provide its services, including for the purpose of tracking data subject interactions with digital advertising supplied through Conversion People’s services.  Publisher shall contractually require its customers to implement appropriate notice and consent mechanisms upon their digital properties so that Conversion People can serve Cookies lawfully through such properties in order to perform its services under the MSA.  Upon request, Conversion People shall provide Publisher with such information as Publisher or its customers may reasonably require about Conversion People’s Cookies in order that Publisher’s customers may provide Cookie notice and consent mechanisms that comply with Privacy Laws.  Conversion People shall not use Cookies to collect data from any individual who has opted-out of Conversion People’s Cookies.

 

  • Survival. This Agreement shall survive termination or expiration of the MSA and/or IO the parties have signed.  Upon termination or expiration of the MSA and/or IO, Conversion People may continue to process the Data provided that such processing complies with the requirements of this Agreement and Privacy Laws.