Munch Content Platform Ltd.
The term "company", "us", "we" or "our", refers to Munch Content Platform Ltd., the owner of the Website.
The term "you", "your" and "yours" refers to any person or entity accessing or using the Website.
The term "personal data" means any information relating to you which allows us or any third party to identify you, whether directly or indirectly.
By accessing, viewing and/or using the Website, you consent to:
· To the transfer of such personal data outside of the country where you reside in and outside the U.S.A., the UK and the European Economic Area ("EEA") and/or other regions with comprehensive data protection laws, to other countries worldwide for storage, processing and use by us, and to the transmission of data on an international basis; and
· The placing of cookies on your computer or internet-enabled device, as described below.
What personal data do we collect?
We may collect the following categories of personal data:
· Log data: Ourservers automatically record information created by your access, viewing anduse of the Website and sent to us by your computer, mobile phone or other access device. Such data is collected by server logs and cookies (see explanation below), and may include information such as IP address and login information, device ID or unique identifier, device type, geo-location information, operating system and browser type, the date and time of visits tothe Website, the pages viewed or searched for, time spent at our Website, and the Internet sites visited just before and just after our Website.
· Our services: We collect personal data and information concerning a person for the purposes of assessing whether we may enter into a business relationship with that person, and subsequently in the course of that business relationship. Such personal data may include your full name; contact information; your financial information e.g., in relation to paying for services; your image; personal data provided to us by you or generated by us in the course of providing legal services to you; and any other information you chose to share with us.
[Munch –are you collecting other types of data?]
You may also give your consent for the processing of your personal data for one or more specific purposes.
· Contacting us: If you contact us through the Website, email or otherwise contact us, we may keep your message, email address and contact information to respond to your request. Providing such information by you is entirely optional.
Cookies and site tracking
A cookie is a small text file, which often includes an anonymous unique identifier. When you visit an Internet site, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each Internet site can send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits an Internet site to access the cookies it has already sent to you, not the cookies sent to you by other sites.
Most web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended.
As you use our Website, the Website uses its cookies to differentiate you from other Users. Cookies, in conjunction with our Internet server's log files, allow us to calculate the aggregate number of people visiting our Website and which parts of the Website are most popular.
In addition, this Website uses the following services:
· Google Analytics. Google Analytics is a web analysis service provided by Google Inc., which works using cookies. This helps us gather feedback in order to constantly improve our Website and better serve our customers. Information about cookies used by or in connection with Google Analytics can be found at:
[Munch: add additional tools if relevant]
What do we use your personal data for, why and for how long?
Purposes for collecting and processing your personal data
We use the information you provide primarily for the following purposes:
· Supply information you request;
· Answer your questions;
· Analyze your use of our products and services, evaluate our performance and improve andoptimize our products, services and Website;
· Compliance with legal and regulatory obligations;
· Facilitating the access, viewing and use of the Website by you;
· Contacting you in the event it becomes necessary to do so;
· Accounting, billing and auditing;
· Protecting our rights and/or the rights of third parties; and/or
· Sending you, from time to time, marketing communications regarding our services.
You will have the right to opt in or to opt out of such marketing communications. You will also be given the opportunity on every marketing email that we send you to indicate that you no longer wish to receive our direct marketing material.
[Munch: delete/add additional use if relevant]
The legal basis for collecting and processing your personal data
We shall only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we process and store your personal data for.
Such legal basis may be one or more of the following:
· You have given your consent to us processing your personal data (e.g., as set out in the Section 'Your consent' above);
· Processing is necessary for the performance of the contract between us;
· Processing is necessary for compliance with a legal obligation which applies to us;
· Processing is necessary to protect your vital interests or those of another person; and/or
· Processing is necessary for the purposes of the legitimate interests pursued by us or by at hird party.
We use your information to produce aggregate insights that do not identify you. For example, we may use your data to generate statistics about our users, their profession or industry, the number of ad impressions served or clicked on, or the demographic distribution of visitors to the Website.
Retaining your personal data
We shall not retain your personal data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations (e.g., in relation to claims) or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data, we shall take reasonable measures to securely delete or destroy it.
Sharing your personal data
We may share your personal data with the following third parties and/or in the following circumstances:
· Service providers we are using to run our business, such as cloud services providers who support our business processes and/or store our data, located in multiple locations world-wide;
· Government authorities, law enforcement bodies and regulators for compliance with legal obligations which apply to us;
· Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in, in order to enforce our legal rights in relation toour contract with you;
Security of your personal data
· We implement what we believe to be appropriate security measures in the storage and disclosure of your personal data, to safeguard it against accidental loss, use or access in an unauthorized way.
· However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, used, disclosed, altered, or destroyed by breach of any of our physical or technical safeguards. You hereby acknowledge and agree that your submission of such information is at your sole risk, and we hereby disclaim any and all liability for any disclosure, loss or liability relating to such information in any way.
· We do not have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information.
Your data protection rights
Under certain circumstances and only to the extent such rights are provided to you by applicable by law, you have the following rights:
· Right to be informed: You have a right to request information about whether we hold personal data about you, and, if so, what that data is and why we are holding/using it.
· Right of access: You have a right to request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Right of rectification: You have a right to request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
· Right to erasure: You have a right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
· Right to restriction of processing: You have a right to request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
· Right to data potability: You have a right to request the transfer of your personal data in an electronic and structured form to you or to another party (commonly known as a right to 'data portability'). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
· Right to object: You have a right to object to processing of your personal data where we are relying on a legitimate interest(or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
You can object to our processing of your data for direct marketing purposes by unsubscribing from our mailing list (see Section 'What do we use your personal data for, why and for how long?' for more details).
If you want to exercise any of these rights, you can contact us as mentioned in Section 'Contact information' below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you have additional rights concerning access, disclosure, amendment, or deletion (as determined by applicable law), you may contact us at the address or email listed below.
Statement towards children
We do not knowingly collect personal data from children under the age of 18.
If we become aware that a child under the age of 18 has provided us with personal data without verification of parental consent, we shall attempt to remove such personal data from our servers and terminate the child's account as soon as possible.
GDPR Point of Contact
We have appointed GDPR points of contact for your convenience:
Primary: ……………………………………..Designated GDPR Officer).
Secondary: ……………………………………..(Escalation point).
If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority. The Privacy Protection Authority is the lead data protection supervisory authority for State of Israel.
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