Privacy policy

[Last Revised: July 17, 2020]

This Privacy Notice (“Privacy Notice”) set forth GNG AI ISRAEL LTD’s (“GNG AI”, Company”, “we”, “us” or “our”) data protection and privacy practices when collection and processing Personal Data of our websites’ visitors and users of our Services (“user” or “you”).

Note that, this Privacy Notice constitutes an integral part of our Terms and Conditions (“T&C”). Capitalized terms used herein however not defined shall have the meaning assigned to them in our T&C.

You are advised to carefully review this Privacy Notice prior to accessing this website and using our Services, as it provides comprehensive information regarding which types of Personal Data we collect, how do we use it, as well as your rights related to your Personal Data processed by us, all, according to applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”), in the event apply to you.

AT THE OUTSET, PLEASE NOTE:

You are not required by law to provide us your Personal Data (as defined below), however, some of our Services, may require the processing of certain Personal Data, as shall be detailed herein.
Children (as defined under applicable law, and specifically under the age of 18 are not permitted to use the Services nor provide us with any Personal Data.
Applicable laws in your jurisdiction may provide you with certain rights regarding your Personal Data, for example, amend, erase or restrict the processing of your Personal Data, or have access to certain Personal Data. Please review the “YOUR RIGHTS” paragraph below for more information.
We may share Personal Data with third parties in connection with the provision of the Services, or other limited circumstances as specified herein.
If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send our privacy team an email: dpo@gng-ai.com.

WHAT IS PERSONAL DATA, AND WHAT DATA IS COLLECTED ABOUT ME BY GNG AI?

When you access our website and interact with our Services, certain information will be collected, as further detailed below. This includes two types of information:
“Personal Data” or “Personal Information” (subject to applicable law definitions) - meaning information that identifies an individual or may with reasonable effort identify an individual. This may include online identifiers such as IP address, name, emails, etc.,

“Non-Personal Data” - meaning technical and aggregated data about your interaction with the website and Services, that is non-identifiable and non-personal (i.e., cannot identify you).

We may collect the data, either by automatic means and tracking technologies such as cookies (as further elaborated below), or when you voluntarily provide us your information, for example, when you sign up to our newsletter and provide us with your email address.

EU General Data Protection Regulation (“GDPR”) & Lawful Basis for Data Processing

We have included below information about which data is processed, how we process and use your data, but before, we would like to explain the lawful basis for which we do so subject to the GDPR:

Where you access the website and use the Services, we process certain Personal Data, such as your IP address, where we have a legitimate interest in processing such data.
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.
We will also process certain Personal Data where you have provided us with consent to do so, if applicable.

As defined under the GDPR, we act as a Controller of the Personal Data we collect and detailed below. We have designed the table below in order to enable you to clearly understand the data collected as well as purpose of use.

	DATA WE COLLECT	PURPOSE OF COLLECTION AND USE
Technical Data, Internet Protocol Address	When you interact with the website and use our Services, we will collect your Internet Protocol address (“IP”). Note that, when you use our Services and directed to our business partner’s sites, our system may generate an internal user identifier known as “Click ID”. In addition, we will collect technical data transmitted from your device such as your type of device, operating system, statistics, type of browser, language preference, time and date you access and use the website and Services, approximate geographical location (that may be extracted from your IP address) and traffic source which lead to the website.	Collection of the IP address is needed both for website’s operation, security and fraud detection purposes, as well as under our legitimate interest, in order to operate our business, for example, in order to calculate payments from our business partners (for this purpose, a Click ID is also created). IP address may be collected by us, or by third party services (as detailed under our Cookies Notice, including for remarketing purposes. In addition, we will use this data for auditing and tracking use of our website, to further enhance and develop our website and the content available therein
Contact Us & Customer Support	If you voluntarily contact us through any means of communication we provide (e.g., send us an email or use any online form available in our website), you will be requested to provide us with your contact information such as your name and email address.	We will use your contact details and save your contact history with us in order to respond to your inquiry, provide you with support, assistance or any other service requested by you. 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).
Newsletter Subscription	Our website may include an online form enabling you to sign up to receive our newsletter or other marketing materials provided by us. If you wish to subscribe, you will be requested to provide us with your email address and your name.	Your information will be used for the sole purpose of sending you our newsletter. You are able to unsubscribe at any time by clicking the “unsubscribe” link which will be included in the email we will send you. You may also contact us at: dpo@gng-ai.com and request to unsubscribe. We are using MailChimp as our service provider for the purpose of email marketing. You may review MailChimp’s privacy policy HERE.
Your Comments & Reviews:	Our website may include a feature enabling you to post your comment or review regarding certain service or product. In order to post you comment, you will be requested to provide your name and email address. Alternatively, you may connect through your social media account (Facebook, Google+, LinkedIn, etc.). When you log in through social networks, we will have access to certain information available in your account, for example, name, email, gender, profile picture, and other information you made public.	Your information will be used for the purpose of posting your review or comment. including for internal authentication process. Note that, if we will decide to post your comment or review, it will be under the information provided by you (name, profile picture), however we will not post your email address. In addition, in the event your email address is associated with your Gravatar account, we may post your comment and review using such Gravatar. We may also send you an email in order to notify you that there were comments related to your posted review. You are hereby advised not to include in the content of your comment or review any of your personal information, as it will be publicly posted and available.
Push Notifications	If you choose to subscribe to our push notifications, your IP address and approximate geographical location will be processed.	This information will be used for the purpose of enabling the operation of the push notifications. You are able to unsubscribe at any time through your standard browser settings. We are using PushAlert as our service provider for the operation of the push notifications. You may review PushAlert’s privacy policy HERE.
Contact our Business Partners	Our website may include a feature enabling you to directly contact our business partners (meaning the operators of the products or services we review) through a designated phone number displayed on our websites. When using such feature, you will be assigned with a unique caller ID. Furthermore, your may choose to provide us with certain information such as your name, email address, and other contact details, in order to be contacted by our business partners.	We use this information to perform our contract with you and provide you with services you have requested, as well as in order to calculate payments. We are using Invoca as our service provider for the operation of direct calls and designated phone numbers. You may review Invoca’s privacy policy HERE.
Partner with Us	Our website may include a feature enabling you to contact us if you wish to be provided with information regarding our business operation and partner with us. If you choose to contact us through such form you will provide us your name, email address, phone number, company name,, and other details voluntarily provided by you.	We will use this information in order to contact you

California Consumer Privacy Act 2018 (“CCPA”) & Categories of Personal Information Collected and Shared

Please note that, 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 collect during the previous 12 months period:

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.	Yes
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

As required under the CCPA, please see below information regarding 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 and (F) Internet or other similar network activity.

We disclose your Personal Information for a business purpose to the following categories of third parties: Data aggregators; Service providers, Business Partners.
Personal Information disclosed by us for a business purpose, is subject to contractual obligations on behalf of the service provider to not use this data for any purpose except performing its obligations under our engagement.

Sale of Personal Information

In the preceding twelve (12) months, Company has not sold Personal Information

DOES GNG AI USE COOKIES AND TRACKING TECHNOLOGIES?

Yes. We use cookies (small text files stored in a user’s browser), web beacons (electronic images that allow to count visitors who have accessed a particular page and to access certain cookies), pixels and other similar technologies. The use of cookies may involve collection of Personal Data, such as IP address. Please see our Cookies Notice. For detailed information, including how to opt out from cookies

WILL GNG AI SHARE MY PERSONAL DATA?

Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at Company’s discretion. This information does not contain any Personal Data and is used to develop content and our Services.

We share Personal Data only under the following limited circumstances:

With third parties who assist us in operating the Services, conducting our business, expanding our business or providing you with requested Services, and for personalizing your experience of the Services.
To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases, website, or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
We may share certain limited data with third parties offering different services and platforms to users, including social networks, in order to present Users with offers and services that may interest them on such platforms. The use of data for certain marketing activities allows us to provide the Platform free of charge to our Users.
Persona Data may be shared subject to your consent or request. It is important to note that, un such event, once your Personal Data is shared, it shall be subject to such third party’s practices related to handling and processing Personal Data.
With our business partners, for the purpose of operating our business and Services. As detailed in our Terms, we provide our Services free of charge due to advertising fees we receive from our business partners, which their products or services are reviewed. We may share with such business partners online identifiers or unique identifiers solely for the purpose of calculating our payments.

WHAT CAN I DO TO CONTROL MY PERSONAL DATA?

Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Data that we hold as follows (and subject to applicable law applies to you):

Your right to be informed: You have the right to be informed with Company’s details (e.g. name, contact details, etc.), as well as information related to why and how we process Personal Data, and additional information necessary to ensure the fair and transparent processing of Personal Data. This Privacy Notice provides you with the required information.
Reviewing and amending your Personal Data. You are entitled to request to obtain confirmation from us that we process certain Personal Data related to you and a right to obtain a copy of that information, together with details regarding how and why we use such information, and details about the source of the Personal Data if not provided by you. Note that, the GDPR and CCPA provide different protections, the GDPR enables access to all Personal Data processed by the controller, however the CCPA "Access Right" applies only to Personal Information collected in the 12 months prior to the request. In the event any Personal Data is incorrect or outdated, you may update and correct such data.
Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law, and for example, and as long as we do not have a legitimate reason for retaining the data, the data is no longer needed for the original purpose and no new lawful purpose exists for continued processing; the lawful basis for processing is consent of the data subject and such consent is withdrawn; the Personal Data is processed unlawfully. You may also limit the purposes for which we may process your Personal Data. Our processing activities may be restricted if, for example, the accuracy of the data is contested; processing is unlawful and you request restriction instead of erasure; or consideration of overriding grounds in the context of an erasure request.
Right to Object & Opt-Out. Under the lawful basis of our legitimate interests and with regards to Personal Data processed by us, you may object to our processing on such grounds. However, even if we receive your objection, we will be permitted to continue processing the Personal Data in the event that, for example, our legitimate interests for processing override your rights, interests and freedoms. See our Cookies Notice for more information regarding opt-out.
Right to withdraw consent. Where we process Personal Data based on your consent, you are entitled to withdraw consent at any time.
Portability of Personal Data. To the extent applicable to you and to the Services, you may request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
Nondiscrimination. Under the CCPA, you must not be discriminated for exercising any of your rights, including by denied goods or services, charging you with different fees for goods or services. Notwithstanding the above it is allowed to set up schemes for providing financial incentives and you can opt-in to become part of them.
Submit a complaint. You may exercise your right to file a complaint to a supervisory authority in your jurisdiction.

If you wish to submit a request to exercise your rights please download our designated “Privacy Rights Request” form available HERE and send it to our privacy team at: dpo@gng-ai.com. When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law.
Where the Company cannot enable you to exercise your rights, you will be provided with a notice explaining the reason.
Data protection and privacy related legislation in your jurisdiction may provide you with additional or different rights.

DATA RETENTION AND SECURITY

We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analyses and improvement of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.
We use physical, technical and administrative security measures for the Services in compliance with industry standards in order to prevent your Personal Data from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost. 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 Please contact us at: dpo@gng-ai.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 Notice 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.
For more information related to our security practices, please review our Security Policy

WILL GNG AI TRANSFER MY PERSONAL DATA INTERNATIONALLY?

Our databases are located in the EU and US. Some of our processing activities are made in other countries. Any transfer of Personal Data (for example outside the EU) to a third country shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our users' rights.

THIRD PARTIES’ CONTENT AND LINKS

As part of our Services, our website includes links to our third party business partners’ websites, landing pages, or other digital assets (“Third Party Digital Assets”). Please be advised that, once you leave our website and access the Third Party Digital Assets, such third party’s privacy notice and practices will govern the collection of your information. We have no responsibility, nor do we monitor these third parties’ privacy practices, so please review their privacy policy to acknowledge such practice.

CHILDREN’S DATA

Our website is a general audience site which is not directed to persons under 18 years old. In addition, our Services are not intended to persons under the age of 18 years old. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases

DO NOT TRACK DISCLOSURE

The website or our Services does not respond to Do Not Track signals. For details regarding Do Not Track signals, please review the following link: http://www.allaboutdnt.com/.

QUESTIONS OR CONCERNS REGARDING PRIVACY

f you have any questions or concerns regarding privacy issues, please send us a detailed message to dpo@gng-ai.com and we will make every effort to resolve your concerns without delay.

You may also contact at:
GNG AI ISRAEL LTD

Yigal Alon 94 tel aviv, 6789139