PRIVACY POLICY
Last modified: April 13, 2020
Togo Networks Ltd (“Togo Networks Ltd” or “us” or “our”) adheres to the practices detailed in this Privacy Policy (“Privacy Policy“) in respect of your use of our Extension and Services (as defined in our End User License Agreement TOS (“TERMS OF USE”)). We respect our users’ privacy and we have designed this Privacy Policy so that you can clearly understand our privacy and data collection practices. We recommend you read this Privacy Policy carefully prior to downloading, accessing or using our Extension and Services. This Privacy Policy is an integral part of our TOS. Definitions herein shall have the same meaning as defined therein.
This Privacy Policy explains what information we may collect from our users, how such information may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as such term is defined below) under the following legislation:
- The EU General Data Protection Regulation (“GDPR”), which shall apply to you in the event you are a resident of the European Economic Area (“EEA”); and
- The California Consumer Privacy Act of 2018 (“CCPA“) which shall apply to you in the event you are a “California resident”, as defined under the CCPA.
If you have any questions about this Privacy Policy, please contact us at: support@togonetworksltd.com
THE HIGHLIGHTS
- You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. Some of our Services however, may depend on providing us with certain Personal Data, as specified below.
- Children under the age of 16 are not permitted to use the Services or provide us with any Personal Data.
- You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data, all as detailed under this Privacy Policy.
CHANGES TO THE PRIVACY POLICY
We reserve the right, at our discretion, to revise or update this Privacy Policy at any time and every 12 months in the event required under applicable law. Such changes shall be effective upon publication of the amended Privacy Policy. The last revision will be reflected in the “Last Modified” heading. PLEASE MAKE SURE TO REVIEW THIS PRIVACY POLICY PERIODICALLY. In the event of material changes that will adversely affect your use of the Service or the data collection by us, we will make best efforts to provide you with notification through the Service.
THE INFORMATION WE COLLECT AND PURPOSE OF USE
We collect non-identifiable aggregated information (“Non-Personal Data”) about your device and your use of the Services. In addition, we collect data that identifies a user or may identify a user (“Personal Data”). All, as detailed below.
EU General Data Protection Regulation (“GDPR”) & Lawful Basis for Data Processing
Depending on the nature of your interaction with Togo Networks Ltd, our lawful basis for collection of Personal Data, as required under the GDPR, is as follows:
- We process certain online identifiers (as described below) during a user’s use of our Services and for functionality and operational purposes, which we have a legitimate interest in processing;
- We and our third-party partners may use cookies for advertising purposes, which, subject to applicable law requirements, we will request your consent for us to do so; and
- In the event you contact us, we will process your contact details and other information you choose to provide us with in order to perform our contract with you.
The types of data that we collect as well as the purpose for processing such data are specified in the table below.
| DATA WE COLLECT | PURPOSE OF COLLECTION AND USE |
| Technical Data and Online Identifiers:When you download the Extension and use the Services, we will collect your Internet Protocol address (“IP”). In addition, we will collect technical data transmitted from your device such as your aggregated use of the Service, statistics, type of browser and default search preference, operating system type, language and the time and date you access and use the Service, website which you lead you to the Services, approximate geographical location, Internet Service Provider (ISP), |
Collection of the IP address is necessary for operating and providing the Services, to further improve, refine, customize and develop the Extension and Services, as well as to perform research, and conduct associated analytical and statistical activities, detect fraud, security or technical issues in connection with the Services and calculate payments. Note that, we will not store your IP address as is, rather use standard industry-wide practice to anonymize the IP immediately upon collection. We will also use this data to assist us in implementing the advertisements incorporated within the Services (where applicable). For example, your IP address may be used to determine your approximate location and thereby assist us in displaying relevant advertisements that will be suited for your needs. We will use industry common means to anonymize this data. |
| Search Queries:We, or our third party partners (providing the search feed) may collect some of your search history such as the URLs of websites that you visited which in most cases is aggregated Non-Personal Data, however, sometimes web browsing data contains terms that could be considered to be Personal Data. This data is deleted shortly after we collect it. | We will use this data for the purpose of providing you with our Services (including relevant advertising based on previous searches that you have done). |
| Contact Details:If you contact us for support and voluntarily provide us with your contact information, including your name and email address. | We will process your contact details and contact history with us only in order to respond to you, provide you with support, assist you or provide you with any other service that you may request. We will retain our contact history and correspondence, in the event we find it applicable (e.g., in the event of future claim, to provide you with support, or to improve our services). |
California Consumer Privacy Act 2018 (“CCPA”) & Categories of Personal Information Collected and Shared
Under the CCPA Personal Information does not include: Publicly available information from government records; Deidentified or aggregated consumer information.
As required under the CCPA, please see below a table specifying the categories of Personal Information we collect:
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | yes |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories. | no |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | no |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | no |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | no |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | yes |
| G. Geolocation data. | Physical location or movements. | no |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | no |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | no |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | no |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | no |
Disclosures of Personal Information for a business purpose:
In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose: (A) Identifiers; (F) Internet or other similar network activity.
We disclose your Personal Information for a business purpose to the following categories of third parties: service providers & data aggregators (e.g. for analytics purposes), business partners (for fraud detection and payment calculation, as well as feed providers, which their feed is implemented as part of the Services).
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 performing the contract.
Sale of Personal Information
In the preceding twelve (12) months, Company has not sold Personal Information.
HOW WE COLLECT DATA
Depending on the nature of your interaction with the Services, the above detailed data is collected as follows:
- In the event you voluntarily choose to provide us with information, e.g., when you contact us.
- Automatically, including through the use of cookies (as detailed below), and other similar tracking technologies.
We will ask for your consent to collect Personal Data and offer you the choice to opt-out of such collection if we are required to do so in accordance with applicable law.
SHARING DATA WITH THIRD PARTIES
We do not share your Personal Data with any third parties. However, we may disclose such information if we have a good faith belief that the disclosure is reasonably necessary in order to: (i) comply with applicable law, regulation or governmental request and collaborate with law enforcement; (ii) enforce our policies and agreements, and establish or exercise our rights to defend against legal claims; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) prevent harm to the rights, property or safety of us, our users, yourself or any third party; and (v) enforce intellectual property or other legal rights.
We will also share online identifiers in order to calculate our business partner’s payments and to detect fraud;
The Non-Personal Data we collect may be used or shared for the same purposes as detailed above with respect to Personal Data, as well as for the purpose of providing and improving our services, internally within the Company to conduct business and marketing analysis. We may share such information with third party service provider partners (i.e. ad tracking, service functionality and support, etc.) and other third parties, in order to assist us in analyzing how our Services are used, and in accordance with the terms of this Privacy Policy.
In addition, we may share your information with a parent company, subsidiaries, joint ventures, or other companies under common control solely if and when applicable or necessary for the purposes described in this Privacy Policy. We may share information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale), provided however, that our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;
DATA TRANSFER
We may process data in the US or in other countries. If you are a resident of the European Economic Area (“EEA“) we will take appropriate steps to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.
COOKIE POLICY
We or our third-party service providers may use cookies. Cookies are small text files that are placed on your device. They are widely used in order to make websites work more efficiently, as well as to provide the Services and functionalities for users, and make the interaction between you and Togo Networks Ltd or Services quicker and easier. Cookies enable you to improve your experience or remember your actions and preferences. More information about cookies is available at: www.allaboutcookies.org.
The specific cookies and other tracking technologies we currently use as part of the Services, purpose of use, their privacy policies and opt-out controls are set forth in the table below:
| Third Party Cookies | Purpose | Privacy Policy |
| Analytic, Measurement & Performance Cookies | https://www.facebook.com/about/privacy/update https://www.facebook.com/policies/cookies/ |
|
Google Analytics |
Essential, Functionality, Operation. & Security Cookies | www.google.com/policies/privacy/partners.https://tools.google.com/dlpage/gaoptout/. For additional information of our use of Google products, click here. |
| Jeeng | Targeting & Advertising | https://www.jeeng.com/privacy-policy/ |
Cookies opt-out
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. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited. For more information about your controls in this regard, you may review the following links: Google Chrome ; FireFox ; Internet Explorer ; Safari ; Edge ; Opera.
Please note that we may offer third party’s search feed as part of our Services which may include its own cookies. Please ensure to review the applicable third party’s privacy policies.
It is important to note that you will not be able to prevent advertisements from being displayed entirely by disabling cookies, rather, the advertisements that you do receive, will not be customized specifically for you.
THIRD PARTY CONTENT
This Privacy Policy does not cover third-party services, third party providers or third party websites or your access and use of such. Those privacy practices may differ from ours, and we do not control the privacy and security practices and policies of these third parties and their sites. We are not, and won’t be held responsible to such privacy practices. Thus, we recommend you to carefully review the applicable third-party privacy policy.
YOUR RIGHTS
You may remove the Extension and reset your device settings at any time.
Depending on applicable data privacy and related laws in your jurisdiction, you may have certain rights in respect of your Personal Data, including the right to access your Personal Data, request to delete, correct or amend it.
For more information regarding you rights please review our Privacy Rights Overview Privacy Rights
If you wish to exercise any of your rights, please fill out the Data Subject Request (“DSR”) form available here, and send it to our privacy team at: support@togonetworksltd.com
DATA RETENTION AND SECURITY
We retain the information we collect solely for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal or tax requirements, or if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints. We use high security techniques to prevent your information from being accessed, used or disclosed without authorization, unlawfully destructed or accidental loss. However, although we make best efforts, we can’t provide 100% security and we cannot be held responsible for unauthorized or unintended access that is beyond our control. If you believe that your privacy was treated not in accordance with the provisions herein, or you have reasonable concern with that any person attempted to abuse our Service, please contact us support@togonetworksltd.com
DO NOT TRACK DISCLOSURE
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/.
CONTACT US
If you have any questions about this Privacy Policy, please contact us at:
Togo Networks Ltd
Derech Begin 132 Tel-Aviv, Israel
support@togonetworksltd.com