Privacy Policy

Last Updated: March 2023

INTRODUCTION:

This privacy policy (“Privacy Policy” or “Policy”) describes how Kueez Entertainment Ltd. (“Kueez”, “we”, “us”, or “our”) collects and uses, certain information, including your Personal Data and the choices you can make about your Personal Data we process.

Kueez is a supply-side platform provider which enables digital assets owners (“Publishers”) and third-party advertisers and advertising networks (“Advertisers” and collectively with Publisher the “Partners”) to manage their advertising inventory (“Advertising Services”).

This Privacy Policy governs the processing of data collected by Kueez in connection with: (i) visitors of our website, available at: https://weare.kueez.com/ or other official digital assets, such as our social media accounts (“Visitors” and "website" respectively); (ii)  Publishers and Advertisers (and each of their authorized users) signing up (or log in) for and use of Kueez Services, including a designated account (“Partner Account”) dashboard environment, marketplace, execution of marketing campaigns, etc. (“Kueez Platform”); and (iii) Publisher's end users (“End Users”).  

Advertising Services, Kueez Platform and the Website shall be collectively referred to herein as the “Services”. Visitors, Publishers and End Users shall be further, separately and collectively, referred to herein as “you”.

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time. You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the best experience of using our Services.

DATA CONTROLLER:

Kueez Entertainment Ltd., incorporated under the laws of the State of Israel, is the "data controller" (as such term is defined under the EU General Data Protection Regulation known as the “GDPR” or equivalent privacy legislation) of the Personal Data processed by it.

This Privacy Policy also details the Personal Data we collect from End Users. However, you should review the Publisher’s policies as well, as they further and independently apply to its data collection practices, as well as provide contact information for requests to exercise your rights related to your Personal Data processed by such Publisher.

TYPES OF DATA COLLECTED AND PURPOSES:  

Depending on your interaction with us, we may collect two types of Data from you:

“Non-Personal Data” meaning aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services. We are not aware of the identity of the user from which the Non-Personal Data is collected. Such Non-Personal Data may include aggregated usage information and technical information transmitted by your device, such as browser version, operating system type and version, mobile network information, device settings, and software data.

“Personal Data” (as defined under the GDPR) or “Personal Information” (as defined under the CCPA) meaning individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual.

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health, government identifiers, precise geolocation or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).

The table below details the types of Personal Data we collect, the methods and purpose of such collection, and our lawful basis for processing such Personal Data (where the GDPR applies):

Kueez participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Kueez operates Consent Management Platform with the identification number 1165.

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above.

HOW WE COLLECT YOUR INFORMATION:

• Automatically, when you visit our website or interact with our Services, including through the use of cookies (as detailed below) and similar tracking technologies.
• When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.
• Provided from third-parties.

COOKIES AND SIMILAR TECHNOLOGIES:

We use “cookies” (or similar tracking technologies) when you access our website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and marketing. You can find more information about our use of cookies here: www.allaboutcookies.org.

The cookies we use on are website are:

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may set your browser to block all cookies, including cookies associated with our website and Services, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Below is a list of useful links that can provide you with more information on how to manage your cookies:

• Google Chrome;
• Mozilla Firefox;
• Safari (Desktop);
• Safari (Mobile);
• Android Browser; and
• Microsoft Edge

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

• The Interactive Advertising Bureau (US);
• The Interactive Advertising Bureau (EU); and
• European Interactive Digital Advertising Alliance (EU)

 Additionally, you may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising.

You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:

• On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).
• On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).

Please note that once you choose to opt out or disable cookies, some features of the Services may not operate properly and your online experience may be limited. In addition, even if you do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.

For additional information, please see the User Rights and Opt-Out section below.

DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We share your Personal Data with third parties, including Advertisers and service providers that help us provide our Services. More information about the categories of such third-party recipients is described below:

When we share information with services providers, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Data they receive and to use the Data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).

USER RIGHTS AND OPT-OUT OPTIONS:

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

the following table describes all the rights you are entitled to. Please note that some rights are only available for residents of California. For more information regarding your rights as a California resident, please see the CCPA-Related Information section below or  visit https://oag.ca.gov/privacy/privacy-laws.

Exercising Your Rights

your rights may be exercised by using the Data Subject Request Form, which includes instructions for submitting, the general description of the process, verification requirements, when applicable, and any information the consumer or employee must provide.

Certain rights can be easily executed independently by you without the need to fill out the Data Subject Request Form:

• If you are our Publisher, you can correct certain data provided under your Publisher Account (such as contact information) through the account settings;
• You can opt-out from receiving our emails by clicking the “unsubscribe” link available in the email itself.
• You can use the cookie settings tool on our website to change your preferences.
• You can opt out of interest-based advertising with some of the service providers we use, such as Google and  Google Analytics. Please note that if you opt out of interest-based advertising, some information will still be collected for other purposes such as analytics, and internal operations. You will also continue to receive contextual advertisements, but they may be less relevant to your interests.
• You can use our "Do Not Sell Or Share My Personal Information" link, located at the bottom of our homepage.
• You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulatory services. For more information, please visit:
• Digital Advertising Alliance (US) HERE 
• Digital Advertising Alliance (Canada) HERE 
• Digital Advertising Alliance (EU) HERE  
• Network Advertising Initiative HERE 
• Digital Advertising Alliance AppChoices HERE
• Use the Global Privacy Control (“GPC”) signals. Ad choices settings will vary depending on your browser and device settings. Please note that your opt-out choices will only apply to the specific browser or device from which you opt out. We encourage you to explore your device and browser settings to better understand your choices.

DATA RETENTION:

In general, Personal Data usually will not be retained for more than 24 months. However, we do retain the data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.

The retention periods are determined according to the following criteria:

• where we have a valid a business reason to process your Personal Data, such as the provision of our Services.
• For as long as it remains necessary in order to achieve the purpose for which the Personal Data was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.
• To comply with our regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
• To resolve a claim we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so. However, retention periods will be determined by taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time and in a way that prevents the Data from being restored or reconstructed.

SECURITY MEASURES:

We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures that comply with applicable laws and industry standards, such as minimizing the amount of data that we store on our servers, restricting access to Personal Data by Kueez employees, contractors,  agents, etc. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty that we will always be able to prevent such access.

Please contact us at [email protected] if you feel that your privacy was not managed properly or if you become aware of an attempt by a third party to gain unauthorized access to your Personal Data. We will make a reasonable effort to notify you and the relevant authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

INTERNATIONAL DATA TRANSFER:

We operate globally, and any information that we collect, disclose or share, including (but not limited to) your Personal Data, can be stored and processed in the European Economic Area, United Kingdom and United States, for the purposes detailed in this Policy. To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to data recipients:

• located in the EEA or in the UK;
• located in non-EEA countries or UK which have been approved as providing adequate level of data protection by the European Committee; or 
• who have entered into a legal agreement ensuring an adequate level of data protection, including the Standard Contractual Clauses as approved by the European Committee.

ELIGIBILITY AND CHILDREN PRIVACY:

The Services are not intended for use by individuals under the age of majority, as defined by the applicable law in such individual's jurisdiction of residence ("Minor"). In addition, our technology enables Partners to choose the “safe mode” and “contextual mode” in which we will display solely contextual advertisement and any identifier will be truncated and hashed. Kueez does not knowingly process Minor's information and will discard any data we receive from a user that we find or reasonably suspect to be a Minor immediately upon discovery. Please contact us at: [email protected] if you have reason to believe that a Minor has shared any data with us.

CCPA-RELATED INFORMATION:

This information applies to Partners, Visitors, Publisher's End Users, independent contractors, and other California residents' (“Consumers” as defined under the California Consumer Privacy Act of 2018 ("CCPA") and amended by the Consumer Privacy Rights Act of 2020 ("CPRA"), or "you") Personal Information which we collect directly or indirectly.

Personal Information is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device.

Personal Information does not include: Publicly available information that is lawfully made available in government records; information that a consumer has made available to the public; De-identified or aggregated consumer information, and information excluded from the CCPA’s or CPRA’s scope such as Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA); clinical trial data, and any personal information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Collection, disclosure and sharing of Personal Information

In the preceding twelve (12) months, we have collected the following Personal Information:

Category A- Identifiers: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, IP address or other similar identifiers.

Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): with respect to Partners - a name, address, telephone number. Some personal information included in this category may overlap with other categories.

Category C- Internet or other similar network activity: information on a consumer's interaction with a website, application, or advertisement.

Category D- Geolocation data: approximate location derived from IP address or movements.

We collected such Personal Information from the following categories of sources:

• Directly and indirectly from activity on our website: For example, directly from you when you inquire about our Services via our website, or indirectly, we collect your usage data automatically from measurement tools.
• Directly from you: For example, from forms you complete, contact us and etc.
• Indirectly from you:  we track your activities across the internet, for example, when you view or interact with certain content, web page or ad.
• From third-parties: For example, from vendors who assist us in performing services for consumers, advertising networks, internet service providers, data analytics providers, social networks, and data brokers.

We may use the Personal Information collected for the following purposes:

• To fulfill or meet the reason you provided the Personal Information (support, respond to a query, etc.)
• To improve our Services
• To analyze which types of ads should be provided as part of the Services
• To administer our business and provide the Services
• For marketing our Services
• For analyzing our Services and your use thereof
• To respond to law enforcement
• To enforce our policies, to defend from claims or exercise our legal rights
• Any other reason detailed in this Policy.

We will not collect additional categories of personal information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We do not "Sell" personal information, as this term is defined under the CCPA.

In the preceding twelve (12) months we:

• Disclosed your Personal Information. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except the performance of the contract. We also prevent the recipient from selling or sharing your Personal Information.
• Shared your personal Information. Sharing is defined as sharing your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our Partners to serve such personalized content.  

For more information about the disclosure and sharing of your Personal Information, please see the following table:

Exercising Your Rights Under the CCPA

As mentioned above, your rights may be exercised by using the Data Subject Request Form, which includes instructions for submitting, the general description of the process, verification requirements, when applicable, and any information the consumer or employee must provide.

In addition to the information provided under the User Rights and Opt-Out Options section above, we provide option to opt out of Sharing for Cross-Contextual Behavioral Advertising or Selling Personal Information by using the following opt-out options:

• Kueez is a member of the Network Advertising Initiative (“NAI”): www.networkadvertising.org, and NAI Mobile Device Opt-out page: https://thenai.org/opt-out/mobile-opt-out/.  
• Kueez is a member of the Digital Advertising Alliance (“DAA”): http://www.aboutads.info/choices/.
• California residents who wish to opt-out from having their data used for behavioral advertising, may exercise their right here: https://optout.privacyrights.info/.
• You can turn on a recognized opt-out preference signal, such as  the Global Privacy Control

Authorized Agents

“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:

• When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer do the following:
• Provide the authorized agent signed permission to do so or power of attorney.
• Verify their own identity directly with the business.
• Directly confirm with the business that they provided the authorized agent permission to submit the request.
• We may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

Notice Of Financial Incentive

We do not offer financial incentives to consumers for providing Personal Information.

Requests Metrics

We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median or mean number of days in which we responded to such requests, in the previous year (these metrics are compiled annually and refer to the period between July 1st of the previous year to July 1st of the following year):

Other California Obligations

• Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
• California’s “Shine the Light” law (Civil Code Section § 1798.83): permits employees that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us the Data Subject Request Form available here.

POLICY AMENDMENTS:

The updated date of this Policy will be reflected in the “Last Updated” heading, indicated at the header of the Policy. As required by the CCPA we will review this Privacy Policy every twelve (12) months and amend it as necessary. Where required by applicable law, we will obtain your consent. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices

CONTROLLING VERSION:

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

CONTACT INFORMATION:

If you have any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact our privacy team as follows:

General Enquiries

[email protected].

HaArba'a St. 17, Tel Aviv-Yafo, Israel

Data Protection Representative: Kueez has designated Dr. Andreas Mätzler as its representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. Inquiries regarding Kueez’s EU privacy practices may be sent to Dr. Mätzler at Schellinggasse 3/10, Vienna 1010, Austria, or by e-mail to [email protected] (please add the following subject to all correspondences: 14102729). If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.

DATA PROTECTION OFFICER:

The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. If you have any questions about this Policy, please contact our Data Protection Officer:

[email protected] 

HaArba'a St. 17, Tel Aviv-Yafo, Israel