Recently updated: September 2019

Namogoo Technologies Ltd. (“Namogoo”, “Company” or “We” is committed to your right to privacy. This privacy policy (the “Privacy Policy”) which is incorporated by reference in our Terms of Use, available at: https://www.namogoo.com/terms-of-use/, governs the processing and transfer of personal data/PII collected in connection with our website at https://www.namogoo.com/ (the “Site”), and/or the services available through the Site or otherwise provided by Namogoo (the “Services”) to each person (“User” or “You”) accessing or using the Site and/or the Services.

We value your trust, and therefore strive to present you this Privacy Policy in clear, plain language, so you can quickly find answers to the questions that interest you. If you have any questions about this policy, please feel free to contact us at: info@namogoo.com If you choose to register or submit information to the Site and Services, you agree to the use of such data in accordance with this Privacy Policy.

1. Introduction & Overview
1.1. Introduction

• 1.1.1. Namogoo was established in 2014 to prevent Customer Journey Hijacking. The company’s disruptive technology protects the customer journey for online businesses by identifying and blocking unauthorized product ads injected into consumer web sessions that divert site visitors to competitors and hurt conversion rates. The world’s largest retailers rely on Namogoo to deliver a disruption-free customer experience and consistently increase ecommerce revenue.
• 1.1.2. This Privacy Policy has been created to define the ways in which Namogoo collects, stores, shares, uses, retains, processes and protects Personal Data (as defined below) provided to it.
• 1.1.3. In this Privacy Policy, “Namogoo” refers to Namogoo Systems Ltd. and its “Affiliates”, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership.

1.2. Summary
Below is a limited high level summary of certain terms herein. Please read this Privacy Policy in its entirety along with the Terms of Use: https://www.namogoo.com/terms-of-use/.

• 1.2.1 Collection of Personal Data. In order to provide our Services (defined below), we may automatically collect users’ Personal Data (defined below), provided directly by users through their use of the Services. Users are not obliged to provide it under any mandatory requirement by law.
• 1.2.2. How We Use Your Information. In general we use Personal Data (1) in order to provide our Services to our customers; (2) where we have a legitimate interest to do so (for example for Site’s security purposes and fraud detection); (3) where there is a legal obligation imposed on us or to protect our legal rights; and (4) otherwise with your consent to do so.
• 1.2.3. Lawful Basis. Personal Data is collected and processed by Namogoo in accordance with the applicable lawful basis.
  Cookies, Web Beacons and Third Party Processors. We and our third party service providers use cookies, web beacons and third party tracking technologies as set forth in our Cookie Policy https://www.namogoo.com/cookie-policy/.
• 1.2.4. Links. Namogoo may include or offer links on the Site to third party’s products or services that are subject to their own privacy policies.
  Children. We do not collect Personal Data regarding children. As a precondition to using the Services, you must be over 18 years.
• 1.2.5. Information Sharing. We grant access to your Personal Data, as described below in details, to limited number of third parties, such as our Affiliates, third party service providers and business affiliates who help Namogoo to maintain, support or develop products; to satisfy applicable law; to prevent fraud or harm; to enforce agreements; or in the event of a structural change of part or all of our assets.
• 1.2.6. Data Integrity. We review our data collection to ensure that the Personal Data we process is accurate, complete and current. However, we depend on you to rectify your Personal Data when necessary.
• 1.2.7. Data Subjects’ Rights. You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled. At any time, you may contact us and request to exercise your rights in accordance with applicable law.
• 1.2.8. International Transfers. The server on which the Services are hosted or through which the Services are processed may be outside the country of your residence or from which you access the Services. Uses and disclosures of your Personal Data may involve transfers of your Personal Data outside the European Economic Area (“EEA”). Transfer of your Personal Data outside the EEA will only be made in accordance with the terms herein.

2. What Personal Data by Namogoo and for what purposes

• 2.1.1. What is Personal Data and Non-Personal Data.

“Personal Data”, means information which identifies or may identify an individual, including first and last name, phone number, email address, pictures, billing information, unique online identifiers etc.
Personal Data does not mean information about a company or organization (such as contact information), but does include information about such corporate entity’s employees and consumers.

“Non-Personal Data”, means non-identifiable aggregated data, such as technical data transmitted by the user’s device and aggregated use of the Site by the general public. This data is not used to identify individual Users.

• 2.1.2. Non-Personal Data Processed by Namogoo.
  We collect non-Personal Data regarding use of the Site and the Services, such as the scope, frequency, latency, pages accessed and viewed, interactions with content and materials displayed through our Services, and other technical information regarding the device used to access the Services. This information is not used in order to identify any specific User.
  Non-Personal Data is used mainly for click stream analysis in order to maintain and develop our Site and Services, including among others, in order to measure and understand the level of engagement with the Services, for general business analytics for ensuring the technical functioning of our network, to help prevent fraudulent use of the Services and for developing new services and features.
• 2.2.3. Personal Data Processed by Namogoo
  We collect the following Personal Data, and process it in accordance with the purposes and legal basis specified below.

Type of Personal Data	Purposes of Processing	For EU persons – Legal Basis under the GDPR
Personal Data provided or collected during registration of our customer’s account and during the use of our services. When you register to one of our Services or request a demo, you will be requested to provide certain Personal Data, such as your: name, email address, age, country, occupation, location (city and state), software or platform used, browser type and language, referring pages, landing pages, exit pages and URL, and language.	To administer our relationship with you, and you and your company with our Services. To resolve any disputes, communicate with you regarding customer service and support issues, and to respond to questions or comments and help resolve any problems.	Performance of a contract to which the data subject is a party (or represent such party) or in order to take steps at the request of the data subject prior to entering into a contract. Or, if applicable, for the necessity of processing for the purposes of our legitimate interests.
Leads We may collect the following information regarding leads and prospective customers via our Services, Site or through online forms you fill in via LinkedIn, in connection with our Services (e.g. receive additional information, ask us to contact you, etc.), such information includes: name, address, email, company, job title, phone number, and country.	To administer our relationship and provide the Services.	In order to take steps at the request of the data subject prior to entering into a contract. Or, if applicable, for the necessity of processing for the purposes of our legitimate interests.
Technical Data We may collect technical data from you. This information includes the type of device, operating system and browsers you use, the time and date you accessed the Services, User’s actions (i.e. regarding the User’s viewing of and interaction with the Website, including the web pages the user visited and clickstream), your approximate geographical location, and any redirecting URLs.	We collect this data solely in order to operate, provide, maintain, protect, manage, customize and improve our Website.	Necessity of processing for the purposes of the legitimate interests of Namogoo.
Newsletters and Marketing Materials In the event a you sign up to receive our newsletter or other marketing materials, you will be requested to provide your email address.	We may send you push notifications and send you news and updates in respect of the Services. We may also send you newsletters, e-mails and promotional communications. You may opt-out of this service at any time by submitting a request at the following link: info@namogoo.com or by other means we will make available (e.g. “unsubscribe” link within the applicable email). In addition, the Personal Data provided to Namogoo will allow it to send its customers messages regarding, among other things, updates of information, new products, features and services, special and promotional offers and events of interest.	Your consent. You may easily unsubscribe at any time by contacting us at info@namogoo.com.
Online Identifiers Online identifiers such as your IP address. This data might be collected by us or by our Site and our service providers, including by the use of cookies (in accordance with our Cookie Policy: https://www.namogoo.com/cookie-policy/	To operate, provide, maintain, protect, manage and improve the Site and our Services, their content and the way in which we offer them; for auditing and tracking usage statistics and traffic flow; and for marketing purposes.	Necessity of processing for the purposes of our legitimate interests, or your consent, depending on the cookies used.
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 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.	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.
Career In the event you are interested in joining our team, and wish to submit your CV, you will be required to provide us with your contact details and submit your CV.	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.
Data Regarding End-Users When you use the services of our customers as an end-user (e.g. when you shop in a merchant’s ecommerce platform that has implemented our services) we use certain online metrics, session duration, the domain name that served you to access the customer’s services, sequence of URLs visited, time and performance metric.	To provide our Services to our customers. To operate, provide, maintain, protect, manage, and improve the Services. Performing research, as well as for analytical and statistical purposes. To audit and track usage statistics and traffic flow, audit our customers, detect fraud, for security or technical reasons in connection with the Services.	Performance of a contract between us and our customers.

• 2.1.4. “Special Categories of Personal Data”, means any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person’s health or data concerning a person’s sex life or sexual orientation.
• We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been collected by us, please inform us immediately.
• In all cases of Personal Data access and collection, the information provided will not be disclosed, rented, loaned, leased, sold, or otherwise voluntarily distributed to unaffiliated third parties, other to the extent set forth herein, and will be used solely for the purpose stated herein.
• Children. We do not collect any Personal Data regarding children. As a precondition to using the Services you must be over 18 years of age and any permitted use by your child (as parent or guardian) after providing Company with your reasonable verifiable consent shall be made solely under your supervision and control by using your device and browser, under the Terms. You must not provide us any Personal Data regarding children and if you have reason to believe that a child has provided us with their Personal Data, please contact us at the address given above and We will delete that Personal Data from our databases

3. Will namogoo share my personal data with others?

• 3.1. Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and customers.
• 3.2. We share Personal Data only under the following limited circumstances:
• 3.2.1. With trusted partners and third parties who assist us in operating the Services and conducting our business, such as fraud prevention, bill collection, account maintenance, marketing and technology services.
• 3.2.2. For personalizing your experience of the Services.
• 3.2.3. As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about products, services and communications.
• 3.2.4. We may share your Personal Data with our Affiliates solely if and when applicable or necessary. In addition, we may share information, in the event of a corporate transaction (e.g. sale, merger, consolidation, etc.), provided however, that our Affiliates or acquiring company will be subject to the obligations detailed herein with respect to your Personal Data.
• 3.2.5. 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.
• 3.2.6. Other third parties with your consent or direction to do so.

4. For how long do we retain the data we collect and process?

• 4.1. We retain the data we collect solely for as long as required to fulfil the purposes for which it was initially collected, or for longer periods in the event we are required to do so in order to comply with legal, tax and accounting requirements. In addition, we will retain information we believe is needed in order to protect our rights and interests in accordance with applicable laws. For additional information on our data retention policy in connection with different types of Personal Data, see the below table.

Type of Personal Data	Retention Period
Data regarding our customers	As long as needed to provide you with the Services you have requested and for longer periods in the event, we believe it is required in order to defend our rights and interests, subject to applicable laws.
Data regarding end users	Where such data constitutes Personal Data, we will retain the data for the duration of the term of provision of our Services to our customers, and in addition a reasonable terms for the defense and assertion of legal claims. Non-personal data may be retained indefinitely.
Data regarding leads	For the duration of the term of negotiation with the prospective customer, or for longer periods in the event, we believe it is required in order to defend our rights and interests, subject to applicable laws.
Email address for receiving commercial materials and newsletters	Until the User has opted out of the service.
Career – C.V.	In the event the User has become an employee, for the duration of employment and in addition for as long as necessary to for the defense and assertion of legal claims.
Technical Data	Technical data is retained in a manner which does not enable the identification of any individual, and may be retained indefinitely.
Online Identifiers	As long as needed to provide you with the Services you have requested and for longer periods in the event, we believe it is required in order to defend our rights and interests, subject to applicable laws.

5. Cross-Border Transfer, Processing and Storage of Personal Data

• 5.1. Our data is stored on the cloud in multiple locations in the US and Europe and some of our processing activities take place in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR; the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.
• 5.2. Any other transfer of Personal Data originating from the EU to a third country (other than Israel) 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. The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access the Services and may be outside your country of residence. Some of the uses and disclosures mentioned in this policy may involve the transfer of your Personal Data to various countries around the world that may have different levels of privacy protection than your country and may be transferred outside of the European Economic Area.
• 5.3. Namogoo transfers Personal Data to a third country only if the controller or processor has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available
• 5.4. Personal Data collected may also be processed by Namogoo’s employees operating outside of the EU or one of its Affiliates or vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support of the Services.

6. Links to Third Parties’ Sites

• 6.1. Namogoo may include or offer links to third party products or services. These parties should have separate and independent privacy policies, and Namogoo has no responsibility or liability for the content and activities of these linked sites.

7. Lawful Basis

• 7.1. Personal Data is collected and processed by Namogoo only upon specific consent of the data subjects, including the consent provided under this policy, unless another legal basis applies.

8. Rights of Data Subject.

• 8.1. Accuracy. Namogoo processes Personal Data only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service agreements. We review our data collection, storage and processing practices to ensure that we only collect, store and process the Personal Data needed to provide or improve our Services. We take reasonable steps to ensure that the Personal Data We process is accurate, complete, and current, but we depend on our users to update or correct their Personal Data whenever necessary. Nothing in this policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.
• 8.2. Right of Access and Rectification. You have the right to know what Personal Data we collect about you and to ensure that such Personal Data is accurate and relevant for the purposes for which we collected it. We allow our Users the option to access and obtain a copy of their Personal Data and to rectify such Personal Data if it is not accurate, complete or updated. However, we may first ask you to provide us certain credentials to permit us to identify your Personal Data.
• 8.3. Right to Delete Personal Data or Restrict Processing. Namogoo supports the data subjects’ “Right to be forgotten”. Data subjects may request to remove their Personal Data at any time by a web request related to the GDPR rights established in the “contact us” form on the Site. You have the right to delete your Personal Data or restrict its processing. We may postpone or deny your request if your Personal Data is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.

6.4. Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your Personal Data. Exercising this right will not affect the lawfulness of processing your Personal Data based on your consent before its withdrawal.

• 8.5. Right of Data Portability. Where technically feasible, you have the right to ask to transfer your Personal Data in accordance with your right to data portability.
• 8.6. Right to Lodge Complaint. You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your Personal Data. Data subjects may request to modify their Personal Data at any time by a web request related to the GDPR rights established in the “contact us” form on the official website.
• 8.7. You may exercise the above rights by sending a request to privacy@namogoo.com.

9. Other

• 9.1. Enforcement. Namogoo regularly reviews its compliance with this policy. Please feel free to direct any questions or concerns regarding this policy or our treatment of Personal Data by contacting us as provided above. When we receive formal written complaints it is the Namogoo’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Data that cannot be resolved between the Namogoo and an individual.
• 9.2. Changes to This Privacy Policy. Namogoo may update this policy. We will notify you about significant changes 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 Services. We encourage you to periodically review this policy for the latest information about our privacy practices.
• 9.3. Applicable Laws. The provisions included in this Privacy Policy relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.
• 9.4. Questions. If you have any questions about this policy or concerns about the way we process your PII, please contact us at info@namogoo.com or via regular mail to: Namogoo, 8 HaSadnaot St., Herzliya, Israel 4672835. If you wish to delete all information regarding your use of the Services, please contact us at: privacy@namogoo.com.