OpenWeb Group Privacy Policy

OpenWeb Group Privacy Policy

We, Open Web Technologies Ltd. (together with our subsidiaries and affiliated companies, as set forth in Annex 1 to this Policy – “OpenWeb”, “we”, “our” or “us”) are dedicated to protecting your privacy rights and making our practices regarding the processing of your Personal Data (as defined below) transparent and fair. 

This privacy policy (the “Policy” or the “Privacy Policy“) describes how we collect, store, use and disclose Personal Data regarding individuals who use, interact with, exposed to, and/or sign up to our Services, including visitors to our Websites, our business partners and other end users (“End User(s)” or “you”). 

This Policy applies to all our websites (including without limitation https://www.openweb.com, https://www.adyoulike.com, https://www.jeeng.com or any other domain or subdomain owned and operated by us; collectively, the “Websites”), as well as to all services provided by OpenWeb, including, among others:

• The commenting, forums, and social engagement platform (“Platform”);
• The performance of Cross Advertising and Ad Monetization;
• Email & Newsreader Monetization Services;
• AdServer for Email(“Email AdServer”). 

The Websites, Platform, Email & Newsreader Monetization, Email AdServer and any other features or services described hereunder are collectively referred to as the “Service(s)”. 

This Policy also refers to any processing of Personal Data by us in the context of advertisements we serve on behalf of third-party companies (“Advertiser(s)“), through publishers’ assets  or email providers (“Publisher(s)”), on such Publishers’ properties (“Properties“) via any of the abovementioned OpenWeb Services. 

Please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any Personal Data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your Personal Data, or to have it processed by us or any of our Service Providers (defined below), please avoid any interaction with us or use of our Services. By using the Services, you agree to our Terms of Use into which this Policy is integrated and made part of.

Please note that this Policy does not apply to job seekers. In order to understand our privacy practices in relation to these matters, please refer to our Job Candidate Privacy Notice.

Table of Contents

1. Types of Personal Data Collected, Legal Bases Purposes, and Methods
2. Categories of Recipients We Disclose Personal Data To; Purpose of Disclosure
3. Cross Border Transfers of Personal Data
4. Tracking Technologies
5. Data Subject Rights
6. US Residents
7. Data Security
8. Data Retention
9. Communications
10. User Generated Content
11. Additional Notes
12. Contact us

1. Types of Personal Data Collected, Legal Bases, Purposes, and Methods

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

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

“Non-Personal Data” means aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Service. We are not aware of the identity of the End-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.

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.

Below are the details of the categories of Personal Data we collect, the methods and the purposes of such collection:

Directly Identifying Information

• We collect Personal Data of our End Users, our business partners’ End Users and representatives, as well as of prospective business partners. This includes, in each case as applicable for the purpose for which we collected the data, information such as name, surname, email, phone number, username, password, social media accounts, and profile picture. 
• When you interact with our Platform, we collect engagement data, including without limitation the contents of comments you post on the Platform, the manner in which you engage with (such as posts you like or share), and other activity on the Platform (collectively, “Engagement Data“) and associate such Engagement Data with your Personal Data. 
• You may voluntarily provide us with your Personal Data when you register to our Services (whether directly from you or by using an SSO authentication option, and connecting any of your personal account, e.g., with Facebook, Google or Microsoft), when you contact us through contact forms and demo request forms on our Websites, or otherwise through emails or direct massages you sent us, etc. 
• We may receive your Personal Data from the Publisher with whom you already have an existing account. We may also receive Personal Data (including your professional details) from an organization you represent or associated with, from Service Providers or from other tools and channels commonly used for exploring potential business opportunities (e.g., LinkedIn and data enrichment providers), etc. 

Why do we process such information? We collect and process directly identifying information to provide you with the Services, authenticate your identity, secure your account with us, protect our Services against fraud, abuse or similar types of activity and exercise our legal rights, personalize the Services for you, communicate with you or respond to your requests, perform customer service and support operations, market our Services to you and facilitate, sponsor, and offer certain events and promotions, improve and enhance our Services, and conduct research and analytics. Additionally, we use Engagement Data to better understand your preferences and interactions, and to deliver advertisements and content that are more relevant to your interests and needs.

Technical Information

• We collect your interactions with the Services, for example, likes, preferences, and other interactions within our Services, including with other users on our Services. 
• Additional technical information also includes IP addresses, unique device identifiers, device and operating system, browser version, pages visited, advertisements viewed or clicked on, your non-precise geographic location, log data and other information derived from your interaction with our Services, including through the use of cookies or other Tracking Technologies (see Section ‎‎4below).
• We may supplement this technical information with data obtained from third parties, this may include inferred demographic information, including presumed age, gender, income level and general location (state/city based on IP address). 

We collect and process technical information to provide you with our Services, to personalize and improve them, to identify fraud, abuse or similar activities, to conduct research and analytics, to advertise to you, including by displaying interest based, cross-channel and cross-device advertising and other types of targeted advertising, or contextual advertising. We may also use such information to monitor the performance of our Services and advertising campaigns

We do not process Special Categories of Data as defined under the GDPR, or any other type of Personal Data of a sensitive nature as defined under any applicable law (e.g., Sensitive Personal Information under US Privacy Laws).

We process the foregoing Personal Data under one or more of the following legal bases: 

• Consent: We may process your Personal Data based on your consent, which you grant us at the moment of singing up and creating an account on our Services. We may also rely on your consent such as which you provide us for marketing purposes, for analyzing your interaction with the Services, to communicate with you or respond to your requests, etc. We also rely on your consent which we obtain through our (or our Publishers’) cookie notice and consent management mechanisms in order to implement Tracking Technologies and process information for the purpose of providing our Services. You may withdraw consent at any time by updating your cookie preference settings (further information can be found in Section‎ 4).
• Performance of Contract: Where we process Personal Data about individuals who engaged with us directly to receive our Services, we do so as necessary to fulfill our contractual obligations towards them.
• Legitimate Interest:  We process Personal Data about individuals in accordance with our legitimate interests, such as, as applicable, to provide, improve and enhance our Services, to understand how our Services are used, to optimize our marketing, advertising, customer services and support operations, to maintain the security of our Services, to enforce any applicable terms and conditions of service, and to protect or defend the Services and our rights.
• Compliance with our Legal Obligations:  We may also process Personal Data to comply with any applicable legal obligations to which we are subject, such as, reporting of illegal activity.

2. Categories of Recipients We Disclose Personal Data To; Purposes Disclosure

OpenWeb may disclose your Personal Data with third parties that help us maintain and provide our Services. More information about the categories of such third-party recipients is described below:

• Entities within OpenWeb Group: We may share your Personal Data internally within the OpenWeb Group as described in Annex 1, as necessary for administrative, management, legal or other business-relates purposes, as necessary to operate our Services, to communicate with you, to offer and provide our Services to you, etc.  
• Service Providers: We disclose Personal Data to third parties that perform services on our behalf, such as hosting, storage, analytics, advertising and marketing, database management, user engagement, cyber and data security (collectively, “Service Providers”). We may also share such data with our business, legal and financial advisors. 
• Business Partners: We may disclose Personal Data to Advertisers and Publishers. 
  • We disclose Personal Data to Advertisers to either display advertisements on or through our Services or to manage our advertising on other websites or apps. Advertisers use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you advertising based upon your browsing activities and interests (see further information in Section ‎4 below). Where applicable, we will only do so on the basis of End Users’ explicit consent which is obtained by our Publishers in the normal course of providing our Services to them. More information and options can be found on each of our Publishers’ respective Properties. 
  • We may also disclose your Personal Data to Publishers to whom we provide our Services, for example for analytics, reporting and monitoring purposes.
• Legal and Regulatory Entities: We may disclose any type of Personal Data, in case we believe, in good faith, that such disclosure is necessary in order to enforce our policies, take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, protect the security or integrity of the Service and protect the rights and property of OpenWeb. We may also disclose your Personal Data when requested by legal or regulatory authorities in response to a verified request relating to terror acts, criminal investigations or similar illegal activity, or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.
• Mergers and Acquisitions: We may use and disclose any of the Personal Data in connection with any merger, sale, transfer of any of our assets, investment, acquisition, bankruptcy, or similar event or any corporate transaction.

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

When disclosing Personal Data to third parties, they are required to secure the Personal Data they receive and to use that Personal Data only in compliance with all applicable data protection regulations (such third parties may use other Non-Personal Data for their own benefit).

3. Cross Border Transfers of Personal Data

While privacy laws may vary between jurisdictions, OpenWeb is committed to protect Personal Data in accordance with its privacy policies and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

OpenWeb is headquartered in Israel, a jurisdiction which is considered by the European Commission and the UK Information Commissioner’s Office (ICO) to be offering an adequate level of protection for the Personal Data of UK and EEA residents (“Adequate Country(ies)”). We transfer Personal Data from the EEA and the UK to Israel and other countries which were recognized as Adequate Countries. For data transfers from the EEA or UK to countries which are not considered as Adequate Countries, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission and UK ICO. You can obtain a copy by contacting us at privacy@openweb.com. 

4. Tracking Technologies

Our Services utilize “cookies”, anonymous identifiers, pixels and other technologies (collectively, “Tracking Technologies”). A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing it. You can find more information about cookies at http://www.allaboutcookies.org. cookies and other Tracking Technologies help us provide our Services, secure and improve them, personalize your experience and monitor the performance of our activities and campaigns. We recommend the use of Tracking Technologies, but if you choose to remove or block them, we will respect your choice. You may opt out of such use by contacting us at privacy@openweb.com.

A list of the Tracking Technologies we use, information concerning our Advertisers, their policies as well as additional information about cookies, including our support of transparency and control initiatives and your opt-out options, can be found here.

5. Data Subject Rights

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. 

Depending on your jurisdiction of residency, you may be entitled to the following rights regarding your Personal Data processed by us: 

Right of access:

You have the right to receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data.

Right of portability: 

you have the right to request us to provide you with a copy of your Personal Data;

Right of rectification: 

You may have the right to request rectification of your Personal Data in our control in the event that your believe the Personal Data held by us is inaccurate, incomplete or outdated;

Right of erasure: 

You have the right to request that we erase or delete your Personal Data;

Right to restriction or objection to processing: 

You may have the right to request that we restrict its processing of your Personal Data;

Right to withdraw your consent: 

To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your consent at any time;

Right to limit use and disclosure of your sensitive Personal Data: 

You may have the right to request to limit the collection of your Sensitive Personal Data;

Right not to be subject to automated decision making:

You may have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.

Right to Opt-Out of the Sale or Share of Personal Data: 

In the event that we sell or share your Personal Data for behavioral advertising purposes, you may have the right to submit a request to opt-out of the sale or share of your Personal Data.

Right to non-discrimination: 

You may have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

Please be aware that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain Personal Data about you. 

Additionally, please note that the applicability of some rights may be limited based on the nature of our Services. For example, we do not engage in the sale of Personal Data, and in some cases, we may not retain any Personal Data. Accordingly, and under such instances, the rights to opt out of the sale or to request deletion of Personal Data may not be relevant.

Exercising your rights:

• Users of the Platform – OpenWeb provides the ability to exercise the rights for access and deletion via the ‘User Privacy’ section available on our Platform.
• If you do not use the Platform and you would like to exercise your rights mentioned in the section, please contact us at: privacy@openweb.com. Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your or your authorized agent’s identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with this Policy.
• If you think we have infringed data protection laws, you can file a claim with the data protection supervisory authority in your jurisdiction of residency, as applicable to you.
• In some jurisdictions, you have the right to appeal a rejection of your request. The appeal request shall be submitted to privacy@openweb.com, or using the contact details specified in the “Contact Us” section in the Privacy Policy. If your appeal is denied, certain jurisdictions allow you to submit a complaint via the local attorney general or another competent authority responsible for handling such matters. 
  

6. US Residents

This Section addresses specific disclosure requirements under the applicable laws pertaining to data privacy, data security, and the protection of Personal Information in the United States, including in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Florida, Delaware, New Hampshire, New Jersey, Iowa, Montana, Tennessee, and Minnesota (collectively, “US Privacy Laws“).

6.1 Collection, Disclosure and Sharing of Personal Information

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

Categories of Personal Information	Data Types
Category A – Identifiers	For example, name, surname, email, phone number, username, password, social media accounts, and profile picture
Category B – Personal information categories listed in the California Customer Records statute	For example, name, address, telephone number, profile picture, employment (only from business partners)
Category E – Internet or other similar network activity	Your interactions with the Services, for example, likes, preferences, information included in your comments, and other interactions within our Services, including with other users on our Services. Additional information also includes IP addresses, unique device identifiers, device and operating system, browser version, pages visited, advertisements viewed or clicked on, your geographic location, log data and other information derived from your interaction with our Services.
Category G – Geolocation data (non-precise)	IP address and your non-precise geographic location
Category I – Professional or employment-related information	From our business partners: title or profession, employer, etc.
Category K – Inferences drawn from other personal information	End user profiles reflecting the preferences and interactions with our Services on the Properties (such as, age, gender, income level and interests)

Sources of Information

In the preceding 12 months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

• Directly, through your activity on our Services: For example, from forms you complete on our Websites, interactions (such as comments) on our Platform.
• Indirectly from you: We track your activities across the internet, for example, when you view or interact with certain content, web page or ad, or when we collect your usage data automatically from measurement tools such as those implemented on the Properties.
• From third-parties: For example, from Publishers, Advertisers, Service Providers who assist us in performing the Services for our customers, internet service providers, data analytics providers, social networks, and data brokers.

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

We do not “Sell” but we may “Share” and disclose Personal Information about you, as these terms are defined under US Privacy Laws. 

In the preceding twelve (12) months we may have shared and disclosed your Personal Information, as described below:

Category of Recipient	Type of Data	Discolsed or Shared
Advertisers	Unique identifiers, IP address, user activity data (interaction with Ads)	Shared and Disclosed
Publishers	All types of Personal Information	Shared and Disclosed
Service Providers	All types of Personal Information	Shared and Disclosed
Any Acquirer of Our Business Entities within OpenWeb Group	All types of Personal Information	Disclosed
Legal and Regulatory Entities	Subject to law enforcement or a competent authority request.	Disclosed

When we disclose Personal Information, we ensure that the recipient only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Personal Information they receive, and to use it 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).

Purposes for Collection, Use, & Sharing 

In addition to the practices detailed in this Policy, we also use and disclose the Personal Information we collect for the following commercial and business purposes:

• Auditing related to our interactions with you;
• Legal compliance;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
• Debugging;
• Performing services (by us or our Service Providers);
• Internal research for technological improvement;
• Internal operations;
• Activities to maintain and improve our services; and 
• Other one-time or short-term uses.

6.2 Designating Agents

If you are a California resident, you may only designate an authorized agent to make a request on your behalf if: (i) The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and (ii) you sign a written declaration that you authorize the authorized agent to act on your behalf. The request must: (i) provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, and (ii) describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

6.3 Direct Marketing Requests

California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at privacy@openweb.com.  

7. Data Security

We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We are using industry-standard physical, administrative and technical security measures to protect your Personal Data held with us, including by vendor security assessments, penetration testing, minimizing the amount of data that we store on our servers, restricting access to Personal Data by OpenWeb employees, contractors, agents, and encryption as appropriate. 

However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any other third party. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Service, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the Personal Data you choose to disclose.

8. Data Retention

We may retain Personal Data about you for as long as your account is active or as long as needed for the purposes set out in this Privacy Policy, including to provide you with our Services.

We may also retain and use Personal Data about you to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies. If you stop using our Services, we may store your data in an aggregated and anonymized format, in which case, we may use this data for a longer period without further notice to you. 

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by sending an email to privacy@openweb.com.

9. Communications

We may contact you with important information regarding our Services. For example, we may notify you, through any of the means available to us, of changes or updates to our Services, password reset requests, etc. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

We may also send you messages and other updates about new features, offering, events and special opportunities, as well as information which relate to your interaction with the Service (likes, comments, etc.). If you do not wish to receive such communications, you may notify OpenWeb at any time by changing your communications preferences in your account, by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the communications you receive, or by sending an email to privacy@openweb.com. 

10. User Generated Content

Our Services allow individuals to comment and upload content to the Services, which others may engage and interact with. Such content may include messages, photos, etc. and may also include Personal Data (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Given the nature of our Services, others who have access to UGC may have the ability to share it with third parties. If you choose to submit UGC to the Services, your UGC, including any Personal Data contained therein, will be considered “public” and will be accessible by anyone.

Please note that we do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on our Services or on the Properties, or what others do with information you share with them on such platforms. We are not responsible for the accuracy, use or misuse of any UGC that you disclose or receive from third parties through the forums or email lists.

11. Additional Notes

Updates and Amendments: We may modify this Privacy Policy from time to time, in which case we will update the “Last updated” date at the top of this Privacy Policy, as well as notify you or take other steps as required by applicable law. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy.

Third Party Websites and Services: While our Services may contain links to other websites or services, or may be offered via Properties, we are not responsible for their privacy practices, and encourage you to pay attention when you interact with any such website, service or application of such third parties, and to read the privacy policies of each and every website, service and application you interact with. This Privacy Policy applies only to our Services.

Please be advised that when you post links to/from YouTube, we make use of the YouTube API in order to support the preview of such content. Such activity is governed by YouTube TOS and Google Privacy Policy. We encourage you to review their practices carefully.

Children’s Privacy: Our Services are not designed to attract children under the age of majority (as determined under the applicable laws where the individual resided; “Minors”). We do not knowingly collect Personal Data from Minors and do not wish to do so. If we learn that a Minor is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such Minor. If you believe that we might have any such data, please contact us by email at privacy@openweb.com.

12. Contact Us

EU Representative: AdYouLike SASU has been designated as OpenWeb’s representative in the EU for inquiries regarding data protection matters, and as its point of contact and legal representative for matters concerning the Digital Services Act.  Inquiries related to these matters may be sent in English, using the following contact information:

Email: privacy@openweb.com

Mail: 145 avenue Charles de Gaulle (Bâtiment DESKEO), 92200 Neuilly-sur-Seine

UK Representative: AdYouLike Limited has been designated as OpenWeb’s representative in the UK for inquiries regarding data protection matters, and as its point of contact and legal representative for matters concerning the Digital Services Act. Inquiries related to these matters may be sent in English, using the following contact information: 

Email: privacy@openweb.com

Mail: 235 High Holborn, London WC1V 7LE, United Kingdom

Data Protection Officer: OpenWeb has appointed a Data Protection Officer for monitoring and advising on our ongoing privacy compliance, as well as serving as a point of contact on privacy matters for data subjects and supervisory authorities. Our DPO may be reached by email at dpo@openweb.com, or by mail at: OpenWeb Ltd. (Attn: DPO), Yigal Alon 94, Tel Aviv 6789156, Israel. 

Questions, Concerns or Complaints: If you have any additional comments or questions about this Privacy Policy or if you have any concerns regarding your privacy, please contact us by email at privacy@openweb.com or via mail at OpenWeb Technologies Ltd. (Attn: DPO), Yigal Alon 94, Tel Aviv 6789156, Israel.

Annex 1: OpenWeb Entities Covered by this Policy

Country	Entity Name	Address
USA	OpenWeb Inc.	38 Greene St. New York, US, 10013
Israel	OpenWeb Technologies ltd.	94 Yigal Alon, Building 2, Tel Aviv-Yafo 6706701, Israel
UK	AdYouLike limited.	235 High Holborn, London WC1V 7LE, United Kingdom, 1st Floor
France	AdYouLike SASU.	145 avenue Charles de Gaulle (Bâtiment DESKEO), 92200 Neuilly-sur-Seine
USA	AdYouLike Corp.	38 Greene St. New York, US, 10013
USA	Powerinbox Inc.	38 Greene St. New York, US, 10013