(Last updated: February 20, 2020)
This privacy policy (“Privacy Policy” or “Policy”) governs the data collection practices used by us, Genieo(“Company”, “we” or “us”), while you (“you” or “user”) access and use our website available at: https://www.thewisefeed.com and the Services provided therein (as defined under our Terms of Service https://www.thewisefeed.com/terms).
Our users’ privacy is important to us and we therefore encourage you to read this Privacy Policy carefully prior to accessing or using our website.
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), including 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.
This Privacy Policy constitutes an integral part of our Terms of Service https://www.thewisefeed.com/terms(“Terms”). Definitions used herein but not defined herein shall have the meaning ascribed to them in our Terms.
If you have any questions about this Policy, please contact us at: info@genieo.com
AMENDMENTS
We reserve the right to periodically amend or revise the Privacy Policy, and every 12 months in the event required under applicable law, which will go into effect immediately upon the implementation of the revised Privacy Policy on our website. The last revision date will be reflected in the “Last updated” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you in the event that we implement any changes that substantially changes our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments.
TYPES OF DATA WE COLLECT
During your interaction with our website we may collect aggregated, non-personal non-identifiable information which may be made available or gathered via the users’ access to and use of the website (“Non-Personal Data“). We are not aware of the identity of the user from which the Non-Personal Data is collected. We may also collect from you, during your access or interaction with the website, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information” as defined under applicable law).
If we combine Personal with Non-Personal Data, we will treat the combined data as Personal Data.
EU General Data Protection Regulation (“GDPR”) & Lawful Basis for Data Processing
Subject to applicable law, our lawful basis for processing Personal Data is as follows:
- We process certain online identifiers (as described below) during your use of our website and for functionality and operational purposes, which we have a legitimate interest in processing;
- We and our third party partners (for example Third Party Digital Assets operators) 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.
|
Type of Data |
Purpose of Processing |
|
IP and Technical Data: When you access our website or interact with our Services, we may collect certain online identifiers (e.g. your IP address) as well as technical Non-Personal Data (e.g. your type of operating system, user's agent, the type of your browser, screen resolution, device ID, approximate geographical location, etc.). |
We use this data for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing and improving our website and the way in which we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; and (iv) protecting the security of the website, as well as our and third parties’ rights (subject to applicable law requirements). If we use third party cookies on our website we will obtain your consent if required under applicable law. |
|
Contact Details: If you voluntarily contact us in any manner, or for any requests or to notify us about something, you may be required to provide us with certain information such as your name and email address which we will then process. |
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). Please note that we use Mandrill services for our contact operation. Mandrill privacy policy is available here: https://mailchimp.com/legal/privacy/ We also use OSTicket services for ticketing. |
|
Push Notification: If you voluntarily subscribe to receive push notification on our behalf, we (directly or by our service providers) will process your IP address and approximate geographical location (country).
|
We will use this information solely for the purpose of sending you with the notifications you subscribed to receive. You may unsubscribe from receiving push notifications, at any time, through your standard browser settings. |
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. |
yes |
|
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 calculating payments and fraud detection).
Sale of Personal Information
In the preceding twelve (12) months, Company has sold the following Personal Information: (A) Identifiers; (F) Internet or other similar network activity to our business partners (i.e., advertisers or search feed operators).
HOW WE COLLECT DATA
Depending on the nature of your interaction with the website, 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.
COOKIES
We use “Cookies” and similar tracking technologies on our website. It is important to note that the use of Cookies is a standard practice. A “Cookie” is a small text file that a website places and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various purposes. These purposes include: (i) allowing you to navigate between pages efficiently, (ii) enabling automatic activation of certain features, (iii) remembering your preferences, and (iv) making the interaction between you and our services quicker and easier. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find more information about cookies at www.allaboutcookies.org.
Types of cookies used on our website:
The following are the types of cookies that we use on our website:
- Essential, Functionality, Operation and Security Cookies. These cookies are essential for enabling users' navigation of the website, for the website to function properly, and for security purposes (e.g., to prevent fraudulent use). This category of cookies either cannot be disabled, or if disabled, may result in certain features of the website not working or functioning properly.
- Analytic, Measurement and Performance Cookies. These cookies are used to collect information about how users use our website, in order to improve our services and the way we offer them, as well assess performance of the Website Content and the way it is displayed on our website.
- Targeting and Advertising Cookies. These cookies are set through our website by our advertising partners. They may be used by these companies to build a profile of your interests and show you advertisements that are relevant to you. They work by uniquely identifying your browser and device and allowing the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows us and our advertising partners to, among other things, deliver targeted advertisements that will be of interest to you. This Privacy Policy does not cover the use of cookies by any third party advertisers nor such third party advertisers’ related privacy practices, which have not been reviewed or examined by us. We encourage you to carefully read the privacy policies of all of these third parties to better understand their privacy practices.
We use the following third-party cookies on our website:
|
Cookie Provider |
Purpose |
Privacy Policy |
|
Genieo |
Essential, Functionality, Operation and Security; Targeting & Advertising |
|
|
Google Analytics |
Analytic, Measurement and Performance |
https://policies.google.com/privacy |
|
Google (doubleclick.net) |
Targeting & Advertising |
|
|
|
Targeting & Advertising |
|
|
Jeeng |
Analytic, Measurement and Performance; Targeting & Advertising |
For additional information with regards to our use of Google products, click HERE.
Opt Out:
You may easily opt-out of our website's data collection, sharing process and targeted advertising services by following the instructions below. You may set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. The following are some links which you may find helpful:
- You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services such as the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page.
Please note that once you choose opt out, part of the services provided by us may no longer be available and some features may not work if you revoke the data transfer. In addition, even if you opt-out, you may still receive some content and advertising, however it will not be targeted content or advertising.
SHARING DATA WITH THIRD PARTIES
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:
- Legal Requirement: We will share your information in this situation, only if we are required to do so in order to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with a court injunction, comply with tax authorities, etc.);
- Policy Enforcement: We will share your information, solely to the extent needed in order to: (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
- Company’s Rights: We will share your information in order to establish or exercise our rights to defend ourselves against legal claims when necessary, subject to applicable law;
- Third Party Rights: We will share your information, solely to the extent needed in order to prevent harm to the our rights, property or safety, as well as our users, yourself or any third party’s rights, property or safety;
- Affiliated Companies and Corporate Transactions: We may share your information with our parent company, any of our subsidiaries, joint ventures, or other companies that are under common control with the Company (“Affiliated Companies”) solely if and when applicable or necessary for the purposes described in this Privacy Policy, as well as in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, we will make our best efforts to ensure that our Affiliated Companies or acquiring company assumes the rights and obligations as described in this Privacy Policy.
- Online Identifiers: We may share online identifiers in order to calculate our partner’s payments and to detect fraud.
Business Purpose - we may disclose your Personal Information to a third party for a “Business Purpose” (as defined under the CCPA). 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. We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non Personal Data to third parties, including, inter alia, affiliates, 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.
USERS’ RIGHTS
Data protection and privacy laws may provide you with some of the following principal rights (depending on your jurisdiction) with respect to your Personal Data, which you may exercise:
- The right to access your Personal Data;
- The right to ensure your Personal Data is accurate, complete and up to date;
- The right to have your Personal Data amended (by correcting, deleting or adding information) (under the GDPR));
- The right to object to the processing of your Personal Data (under the GDPR);
- The right to send or “port” your Personal Data;
- The right to file a complaint with a supervisory authority in your jurisdiction (under the GDPR);
- The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice (under the GDPR);
- Right to Non-Discrimination (under the CCPA) - you have the right not to be discriminated against for having exercised your rights under the applicable laws. In particular, the business may not: Deny the consumer goods or services Charge the consumer different prices for goods or services, whether through denying benefits or imposing penalties provide the consumer with a different level or quality of goods or services to the consumer.
- Do not sell (under the CCPA).
For more information regarding you rights please review our Privacy Rights Policy: https://www.thewisefeed.com/prp
In the event that you contact us and request to exercise any of your rights detailed above, we may request that you provide us with certain information in order to verify your identity and locate your data. Such a process may take a certain period of time, as required under applicable laws (for example up to one (1) month under the GDPR or 10 - 45 days under the CCPA, unless an extension period is required).
Please note that you may have different rights than those which we listed above subject to privacy protections laws in your jurisdiction.
If you wish to exercise any or all of the above rights, please fill out the Privacy Rights Request (“PRR") form available here, and send it to our privacy team at: info@genieo.com
DATA RETENTION
Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable.
SECURITY
We use physical, technical and administrative security measures for the services that we believe are in compliance with applicable laws and industry standards in order to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destroyed or accidentally lost, as we further explain in our Security Policy. https://www.thewisefeed.com/security. It is important for you to remember however, that unfortunately, the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via our website or our Services and any transmission of your data shall be done at your own risk.
Please contact us at: info@genieo.com if you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
CHILDREN
Our website is not directed nor is it intended for use by "children" as defined under any applicable laws and specifically under the age of 16, and we do not knowingly process a child’s information. We will discard any information that we receive from a user that is considered a "child" immediately upon our discovery that such a user shared information with us. Please contact us at: info@genieo.com if you have reason to believe that a child has shared any information with us.
TRANSFER OF YOUR DATA
We may store or process your Personal Data in a variety of countries including the United States. Please note, that if you are a resident of the EEA we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection when it is being transferred out of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.
DO NOT TRACK DISCLOSURE
Our website 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, you may contact us as follows:
By sending an email to: info@genieo.com
- By mail at:
6 Hanehoshet St.
Tel Aviv, Israel.
6971070
+(972) 73 230 0100