[Recently updated: October 1, 2022]
Namogoo Technologies Ltd. and its “Affiliates”, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership (“Namogoo”, “Company” or “We”) is committed to protect your right to privacy.
Namogoo may update this policy from time to time to align with changes to applicable laws or practices. We will notify You about any significant change in the way we treat Personal Data by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Website.
If you are a California Resident please see our CCPA Notice available at: https://www.namogoo.com/ccpa.
1. INTRODUCTION & OVERVIEW
Namogoo offers its customers (“Customers”) various services and features, including (collectively shall be defined as the “Service(s)”): (i) a Customer Hijacking Prevention (“CHP”) service, that identifies and blocks unauthorized ads or web sessions, that divert Customer’s end users (“End Users”) from the Customer’s website; (ii) an Interest Based Promotion (“IBP”) services, that offers individualized incentives to End Users in order to increase the business metrics and revenues; (iii) and Shopping Extension Management (“SEM”) which evaluates the traffic generated from shopping extensions and enables the Client to optimize the traffic and conversion; and (iv) as part of the IBP, the Client can choose to implement the personalized email and sms features. (v) online dashboard and account enabling the Customer, its employees and administrators to analyze the data provided by the Services.
2. THE DATA PROCESSED BY NAMOGOO
“Personal Data”, means information which identifies or may identify an individual, including first and last name, phone number, email address, pictures, billing information, online identifiers, etc.
“Non-Personal Data”, means non-identifiable aggregated data, such as technical data transmitted by the user’s device and aggregated statistics relating to the use of the Website by the general public.
[[for ensuring the technical functioning of our network and to help prevent fraudulent use of the Services.]]
In the table below, we detail the data set we may collect in different instances, and the purpose of such processing. It is important to understand, in some cases, such as with Personal Data from Visitors to our Website, we act as the “Data Controller” as defined under the EU General Data Protection Regulation (“GDPR”) or “Business” as defined under the California Consumer Privacy Act (“CCPA”) when we process Personal Data from our Customers , however, we act as a “Data Processor” as defined under the GDPR or “Service Provider” as defined under the CCPA in the event we process Personal Data from an End User, i.e., an individual browsing our Customer’s website, all as further detailed in the table below.
Information Collected from Site Visitors and Customers
|Type of Personal Data||Purposes of Processing||For EU persons – Legal Basis under the GDPR|
Contact Information of Customers and Potential Customers:
Customer employees data, including contact information, payment information, etc. is governed by the Client Agreement and Data Processing Agreement.
If You show interest in our Services by contacting us, signing up to receive a demo, or request we analyze your site (“Potential Customer”), You will be requested to provide certain Personal Data, such as your: name, email address, company, job title, phone number, and country.
|We use the Customer or the Potential Customer data solely to provide the Service or respond to the inquiries.||We process the Personal Data to perform our contract with You, to provide you service, and to pursue similar legitimate business purpose’s.|
We collect the Customer, or the Potential Customer’s email address for Direct Marketing.
|We use the email address provided by the Customer or Potential Customer for direct marketing, meaning we will send You email promotions and updates specifically regarding the Services You are interested in, or, if You are an existing Customer we will also send you information on the Services used and invoices (“Direct Marketing”).||Our legitimate interest in providing You information regarding the Services, you may opt-out at any|
In the event a You sign up to receive our newsletter, as a Visitor to the Site, or other marketing materials, You will be requested to provide your email address.
|We use this information to send updates, commercial promotions, new products, features and services, special and promotional offers and events of interest.||We process this information solely upon receiving your consent. You may opt-out of this service at any time by submitting a request at the following link: mailto:firstname.lastname@example.org or by other means we will make available (e.g., “unsubscribe” link within the applicable email).|
When you interact with our Site or Services, we may collect your Internet protocol (IP) address.
|We process your online identifiers through our Site to enhance the functionality of the Website for analytic and marketing purposes||Consent, though our cookie notice on our Site|
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 use your contact details only in order to respond to You, provide You with support and assist You or provide You with any other service that You may request.||We process the Personal Data to perform our contract with You.|
Non-Personal Data Technical Information:
Clickstream data, scope, frequency, latency of web-pages accessed and viewed, interactions with content and materials, type of device/operating system/browser, time stamp, approximate location (i.e., country level), and language.
|We collect this data in order to process your job application, including assessing suitability, eligibility and/or fitness to work.||Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.|
Information Collected from End Users of our Customers
|Type of Personal Data||Purposes of Processing||For EU persons – Legal Basis under the GDPR|
Where instructed to do so by our Customer we may collect your Internet protocol (IP) address when visiting our Customer website.
|To provide our Services to our Customers, and to enabling our Customer to identify returning End User’s||We process this on behalf of our Customer (as a processor/service provider), therefore, we rely on the lawful basis established by our Customer under the laws applicable to it|
When End-Users access our Customers’ website, they will be assigned with a unique ID, which is a random number we generate (“Unified ID“). We use this data solely to identify that an End-User is the same End-Use when such End-User access again to Customers’ website or for the purpose of providing the Services to Customers.
Although the unique ID does not reveal the identity of a user and is not generated based on any user personal information, it may be considered in some jurisdictions as Personal Information. Therefore, we treat such information as Personal Data, in accordance with applicable laws.
To provide our Services to our Customers, to enable identifying of returning End-Users
|We process this on behalf of our Customer (as a processor/service provider), therefore, we rely on the lawful basis established by our Customer under the laws applicable to it|
Non-Personal Data Technical Information
We collect and process End Users interaction data (e.g. browsing behavior, click-events, page-calls) when they are interacting with our Customer’s website
|To provide Services to our Customers.||We process this on behalf of our Customer (as a processor/service provider), therefore, we rely on the lawful basis established by our Customer.|
If you engage with our Customer which implemented our IBP product we may collect and process certain contact information on behalf of our Customer(i.e. email, name and phone number)
|To provide our Services to our Customers.||We process this on behalf of our Customer (as a processor/service provider), therefore, we rely on the lawful basis established by our Customer.|
3. WILL NAMOGOO SHARE MY PERSONAL DATA WITH OTHERS?
Depending on the nature of your interaction with the Services, we may collect information as follows:
- Provided by you voluntarily – we may collect information if and when you choose to provide us with the information, such as through communications, support, registration, etc.
4. SHARING PERSONAL INFORMATION
We share Personal Data only under the following limited circumstances:
- a) With trusted partners and third parties who assist us in operating the Site and Services and conducting our business, such as fraud prevention, bill collection, account maintenance and technology services, these parties are all obligated to keep the Personal Data protected and are contractually signed on data processing agreements.
- b) With our Affiliates solely if and when applicable or necessary.
- c) With third parties if necessary, 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 or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
5. FOR HOW LONG DO WE RETAIN THE DATA WE COLLECT AND PROCESS?
We retain the data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
For more information on our data retention policy please contact us at: email@example.com
6. TRANSFER OF DATA
We may store or process your Personal Data in a variety of countries including the United States. Further, certain processing activities are conducted in Israel, or in other countries. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, When Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred in accordance with the provisions of the standard contractual clauses approved by the European Union. If You would like to understand more about these arrangements and your rights in connection therewith, please contact us at: Privacy@namogoo.com.
7. RIGHTS OF DATA SUBJECTS
Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Information. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Data they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Data to another party. Please review our User Rights Policy (available at: https://www.namogoo/userights) to learn more about the rights You are entitled to.
If You wish to receive more information or in the event that You have any additional complaints about your privacy rights, please contact us at: firstname.lastname@example.org.
We work hard to protect Personal Data we process from unauthorized access or unauthorized alteration, disclosure or destruction. In doing so we have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry such as: encryption using SSL, data minimization on our servers, restrict access to Personal Data by Namogoo’s employees, contractors and agents, all as further detailed in our Security Policy. Note that, no security measure is 100% failproof, and information may be compromised by circumstances beyond our control which we cannot be held responsible for. We make no warranty, express, implied or otherwise, that we will always be able to prevent such access.
Further, in the event of a data breach, in which we discover your Personal Data is at risk, we will notify you through the Services or, if technically possible, by sending you an email, subject to applicable law requirements.
9. CONTACT US:
If You have any questions about this policy or concerns about the way we process your Personal Data, please contact us at:
email@example.com or via regular mail to: Namogoo, 8 HaSadnaot St., Herzliya, Israel 4672835.
Our representative in the European Union is Ms. Emily Cawse. You may contact our representative at:
firstname.lastname@example.org or via regular mail to: 23-1 Zoomstraat, Amsterdam, 1078XG, The Netherlands