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Privacy Policy

This privacy policy (“Privacy Policy”) outlines Wadi Digital Ltd.’s (“Wadi Digital,” “we,” “our,” or “us”) practices with respect to its collection, usage, and processing of information of those individuals who:

  1. access or visit our website (“Visitors”) available at: www.cyfluencer.com;

  2. use and sign up for our Cyfluencer platform (“Platform”) to either publish its content or blog posts (“Publisher Content” and“Publisher(s),” respectively) or to access and repost Publisher Content on their social media account (“Influencer(s)”). Publisher and Influencers shall be referred to collectively herein as “Partner(s)”; and

  3. click on the Publisher Content that is displayed by the Influencers (“Viewers”).

The website and the Platform shall be referred to collectively herein as the “Services”. Additionally, Visitors, Partners and Viewers shall be collectively referred to herein as “you” or “your”.

This Privacy Policy is an integral part of our Influencer Terms and Conditions and our Publisher Terms and Conditions (as applicable) (each the, “Terms”) each of which shall include additional information and conditions regarding our Services. Any definitions that are used herein and not defined herein shall have the meaning ascribed to them in the Terms

We have included information below regarding which types of data are collected and how we process and use your data. However, before we get into that, we would like to explain the lawful basis upon which we collect, process and use your data (as further explained in the table below):

  1. If you are a Partner, we will process your Personal Data (as such term is defined below) in order to perform our contract with you;

  2. If we have a legitimate interest in processing Personal Data, such as for direct marketing or for security and verification purposes, when you access our website or as part of our Services; or

  3. We will also process your Personal Data where you have provided us with your consent to do so if and as required under applicable law.

For the purposes of the European Union General Data Protection Regulation (“GDPR”), we are considered the Controller (as such term is defined under the GDPR) of the Personal Data we collect from our Visitors and Partners and considered the Processor (as such term is defined under the GDPR) of the Personal Data that we process from the Viewers.

If you are a resident of California, the California Consumer Privacy Act (“CCPA”) may apply to you. Please review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA.

INFORMATION WE COLLECT

We may collect two types of data from you, depending on your interaction with us.

  1. Non-Personal Data: The first type of data is non-identifiable, anonymous and aggregated data that is mainly technical data transmitted by your device and via your use of the Services. (“Non-Personal Data”). We are not aware of the identity of the individual who we collected the Non-Personal Data from.

  2. Personal Data: The second type of data is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

For the avoidance of doubt, any Non-Personal Data that is connected or linked to any Personal Data shall be considered Personal Data for as long as such connection or linkage exists. Furthermore, you are not required by law to provide us with any information and may choose to avoid providing us with certain Personal Data.

Information we collect from Visitors:

cyfluencer privacy policy chart

Information we collect from Visitors:

cyfluencer privacy policy chart

Information we collect from Visitors:

cyfluencer privacy policy chart

HOW WE COLLECT DATA

Depending on the nature of your interaction with us, we may collect information from you in one or both of the following ways

  1. Automatically – we may use cookies (as explained below) or similar tracking technologies to automatically collect some information.

  2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as via communications with us, when you subscribe for our newsletter or when you register for our Services, all as explained in this Privacy Policy.

SHARING INFORMATION WITH THIRD PARTIES

Wadi Digital will not share any Personal Data it collects with any third party, other than under the following circumstances:

  1. Compelled Disclosures – To satisfy any applicable law, regulation, legal process, subpoena or governmental request;

  2. Enforcement of our Rights – To enforce this Privacy Policy and the terms of our agreements (including the Terms), including the investigation of potential violations thereof;

  3. Security Detections – To detect, prevent, or otherwise address fraud, security or technical issues;

  4. Business Transfers and Affiliated Companies – When it is undergoing any change in control, including by means of a merger, acquisition or purchase of all or substantially all of its assets or with our parent company, any subsidiaries, joint ventures, or other companies under common control with Wadi Digital solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of any of the corporate transactions listed herein;

  5. Service Providers – To collect, hold or manage your Personal Data through our authorized third-party service providers, as reasonable for our business purposes;

  6. Explicit Consent – If you provide us with your explicit approval to share your information prior to the disclosure.

COOKIES POLICY AND TRACKING TECHNOLOGIES

We or our third-party service providers may use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with our Services.

A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.

The third-party cookies used on our website are as follows:

cyfluencer privacy policy chart

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 your online experience may be limited.

Please see the following links for more information with respect to how you can block or erase cookies via your particular browser: Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera.

DATA RETENTION

We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual requests to opt-out of such collection, subject to applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.

USER RIGHTS

Depending on your jurisdiction, data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we process (please review our User Rights Policy for more information regarding the rights you may have under the relevant data protection and privacy laws in your jurisdiction).

If you wish to exercise any or all of the above rights, please fill out the Data Subject Request Form (“DSR”) available here, and send it to our privacy team at: privacy@cyfluencer.com.

If we are unable to provide you with the information that you asked for, we will endeavor to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.

SECURITY

We take great care in implementing and maintaining the security of your information. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any of such. We have implemented technical, physical and administrative security measures to protect your Personal Data, including without limitation by using industry standard encryption. In addition, we limit access to your Personal Data on our servers. The data collected by us is stored mainly on Digital Ocean’s data servers in Frankfurt, Germany. Please visit the following link for more information regarding the data security provided by Digital Ocean.

Please contact us at privacy@cyfluencer.com if you believe that your privacy was treated in a way that was not in accordance with this Privacy Policy. In the event of a security incident in which we discover that your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if we are required to do so, subject to applicable laws).

DATA TRANSFER

We may store or process your Personal Data in the EU, the United States or in other countries. Thus, any information you provide us may be transferred to and processed in countries other than the country from which you accessed our website. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer. When Personal Data that was collected within the European Economic Area (“EEA”) is transferred outside the EEA, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data. You may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer

PROTECTING CHILDREN

The website and our Services are not intended for use by individuals who are under the age of eighteen (18). Therefore, Wadi Digital does not intend and does not knowingly collect any Personal Data directly from individuals who are considered to be children in their jurisdictions (i.e., under the age of sixteen (16) or as otherwise defined under applicable law in such jurisdiction), and does not wish to do so. If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardian. If we obtain actual knowledge that a Visitor, Partner or Viewer is considered a child under applicable law, we will take steps to immediately delete his or her Personal Data. We request that such individuals do not provide Personal Data through our website or the Services. Please contact us at: privacy@cyfluencer.com. if you become aware or have any reason to believe that a child has shared any Personal Data with us.

CHANGES TO THIS PRIVACY POLICY

Wadi Digital reserves the right to amend this Privacy Policy at any time. As such we recommend that you re-visit this page frequently and review the Privacy Policy for any changes that we may have made. In the event that we made any substantial changes to this Privacy Policy, we will make reasonable efforts to provide you with notification with respect to such changes, if we are required to do so by applicable law. The changes to this Privacy Policy will go into effect as of the date listed in the “Last Amended” heading located at the top of this Privacy Policy.

CONTACT US

Please contact us if you have any questions (or comments) concerning this Privacy Policy, as follows:

  • By email: privacy@cyfluencer.com.

  • By mail: Wadi Digital Ltd. Gush Chalav 24/1  Pardes Hannah-Karkur, Israel 

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