PRIVACY POLICY
Last Revised: June 19th, 2022
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This Privacy Notice (“Privacy Notice”) set forth Rational Instinct Ltd. ("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 of Use (“Terms”). Capitalized terms used herein however not defined shall have the meaning assigned to them in our Terms.
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.
In the event you are a California resident and the CCPA applies to you – please make sure to review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA.
If you have any questions or requests regarding the processing of your Personal Data, or in case you want to contact us for any other reason in connection with this Privacy Policy, please email us at: privacy@rationalinstinct.com
DATA CONTROLLER & DATA PROTECTION OFFICER
Rational Instinct Ltd. incorporated under the laws of Israel is the controller of your Personal Data.
You may contact us and our privacy team as follows:
By Email: privacy@rationalinstinct.com
By Mail: Alon 2 Tower, Tel Aviv, Igal Alon 94, Floor 31, Postal Code 6789139 WEBIZ-SMART BUSINESS OFFICES
AMENDMENTS & UPDATES OF THIS PRIVACY NOTICE
This Privacy Notice may be updated or amended by us from time to time, at our discretion, including in the event required under applicable laws. Therefore, we ask you to check back periodically to read the most updated Privacy Notice. The last revision will be reflected in the "Last Revised" heading. In the event of material amendments, we will make efforts to post an applicable notice, subject to applicable laws requirements.
THE DATA WE COLLECT & OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
Depending on your interaction with our website and 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, information which does not identify a specific natural person and cannot reasonably be used for such identification. We collect Non-Personal Data regarding use of the Services, such as the scope, frequency, latency, pages accessed and viewed, time and date you have accessed the Services, interactions with content and materials displayed through our Services, language preference, and other technical information regarding the device used to access the Services, for example type of device, type of browser, operating system, etc. This data is considered as Non-Personal Data when collected on an aggregate basis, or otherwise no combined with online identifiers.
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.
Personal Data Processed by the Company
The types of Personal Data collected directly from you or your device through your access and use of the Services are listed below, including the purpose of collection, lawful basis (as required under the GDPR) and processing operations:
Data Set | Purpose and Operations | Lawful Basis |
Online Identifiers When you interact with the website and use our Services, we will collect your Internet Protocol address (“IP”). In addition, when you use our Services and directed to our Third-Party Provides sites or other Third-Party Resources (as defined and detailed under our Terms), our or the Third-Party Providers' systems may generate an internal user identifier known as “Click ID”. | Collection of IP address is needed both for website’s operation, security and fraud detection purposes, as well as in order to operate our business. In addition, this data might be collected for internal statistics and analysis, for example, to analyses how many users have accessed certain content and from which country (where the country is extracted from the IP address) in order to enhance and improve our website and its content. In addition, Click IDs are used in order to track performance and calculate payments generated from our engagement with the Third-Party Providers, meaning, once you interact with Third Party Offer through our website, the Click ID enables us and the Third-Party Provider to identify our website is the source of your interaction, and compensate us. Note that we may combine Online Identifiers with technical No-Personal Data. In such event, the combined data will be treated as Personal Data. In addition, please note that Online Identifiers may be collected by us, or by third party services (as detailed under the Do We Use Cookies paragraph below, including for remarketing purposes. | We process this information for the purpose of our business operation, fraud detection, and internal development, etc., based on our legitimate interests. Where required under applicable laws, we will obtain your consent for the purpose of data collection through third-party cookies. |
Interactions with Third Party Providers In the event you interact with Third Party Offer through our website, the Third-Party Provider will share with us the type of interaction (e.g., purchase, registration, click, etc.), combined with the generated Click ID ("Interaction Data"). | We will use the Interaction Data in order to charge the applicable compensation (i.e., advertising fees) from the applicable Third-Party Provider. We may also use the Interaction Data for internal statistics, and for example, to understand how many users decided to purchase o Third Party Offer and analyze its popularity. | We process such Interaction Data based on our legitimate interest in order to operate our business. |
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). | We process such data subject to our legitimate interest in order to respond to your inquiry. |
Newsletter Subscription In the event you sign to receive our newsletter or other marketing materials ("Marketing Materials"), you will be requested to provide your contact details, such as name and email address. | We will use the information you provide in order to send you our newsletter and other Marketing Materials you have requested or signed up to receive. | We process this data based on your consent. You may withdraw your consent 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: privacy@rationalinstinct.com and request to unsubscribe. |
User Content As a user of our website, we may enable you to post your own comment or review regarding certain service or product displayed on our website. In order to post your comment or review you will be requested to provide your contact information such as name and email address. | We will use your information in order to post your comment or review, including for internal authentication process. Note that, if we will decide to post your comment or review, it might be under the information provided by you (your name), however we will not post your email address We may also send you an email in order to notify you we have posted your review or other content, or when 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. | We process your information subject to your consent provided when posting a comment or review. |
DO WE USE COOKIES?
Yes, we use “cookies” and similar tracking technologies on our website. This includes our cookies as well as third party cookies, which may include our service providers, as well as cookies placed on behalf of the Third-Party Providers we are engaged with. 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 Services:
Essential. These cookies are essential for our website to upload and function, including for security purposes. This category of cookies either cannot be disabled, or if disabled, may result in certain features of the Services not working or functioning properly.
Functionality and Operation. These cookies are used for the purpose of enabling users' navigation of the Services and for the Services to function properly. If you disable this category of cookies, it may result in certain features of the Services not working or functioning properly.
Analytic, Measurement and Performance Cookies. These cookies are used to collect information about how users use our Services, in order to improve our Services and the way we offer them, as well assess performance of the Services and the way it is displayed on our Services.
Preference, Targeting & Advertising Cookies. These cookies are used to advertise across the internet and to display relevant ads tailored to users based on the parts of the website they have visited (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage)
We use the following service providers' third-party cookies on our website:
Third Party | Purpose | Privacy Policy/Opt-Out |
Google Analytics | Analytic | For privacy information, go to: https://policies.google.com/privacy https://developers.google.com/admob/android/ quick-start#import_the_mobile_ads_sdk To opt-out, visit: https://myaccount.google.com/data-and-personalization For additional information regarding our use of Google products, visit: https://policies.google.com/technologies/partner-sites |
Google Doubleclick | Targeting & Advertising | |
Bing | Targeting & Advertising | https://privacy.microsoft.com/en-us/privacystatement |
Hotjar | Analytics | |
Taboola | Targeting & Advertising | |
Yahoo | Targeting & Advertising |
You may set your browser to block all cookies, including cookies associated with our Services, 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. In addition we may further offer you to opt-out of cookies or revise your cookies' setting using a designated tool on our website.
Please note that once you choose opt out, part of the Services and content on the website 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 do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.
DATA SHARING
The Company may share at its sole discretion Non-Personal Data, aggregate and statistical or otherwise anonymized data.
The Company share Personal Data only under the following limited circumstances:
CATEGORY OF RECIPIENT | DATA THAT WILL BE SHARED | PURPOSE OF SHARING |
Company's Service Providers | Contact Information. | The Company may share Personal Data with third parties who assist us in operating the Services, conducting our business, expanding our business or providing you with requested Services. This includes, for example, website operation services, analytic services and advertising partners. When we do so, we ensure that the service providers only have access to such information that is strictly necessary in order for us to provide the Services. |
Third-Party Providers | Online Identifiers. | As detailed in the data collection table above as well as our Terms, we may share with such business partners online identifiers or unique identifiers solely for the purpose of calculating our payments. |
Cloud Service Provider | All data. | Google Cloud Platform provides us with data storage and hosting services. Our servers are located in the US. |
Analytics Service Provider | Online Identifiers. | Please see the section of “Do We Use Cookies” above. |
Legal and Law Enforcement | Subject to law enforcement authority request. | The Company may share Personal Data in order 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. |
User’s Consent | Contact Information. | Persona Data may be shared subject to your consent or request. It is important to note that, in 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. |
Where we share information with services providers, we ensure they only have access to such information that is strictly necessary in order to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).
USERS RIGHTS
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 the “Do we Use Cookies” above for more information regarding your opt-out options.
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.
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: privacy@rationalinstinct.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: privacy@rationalinstinct.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.
DATA TRANSFER
Our databases are located in the US. Some of our processing activities are made in other countries. In the event that we need to transfer your Personal Data 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. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union.
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 Third-Party Resources. Please be advised that, once you leave our website and access the Third-Party Resources, 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, and we do not knowingly collect or solicit Personal Data from children. 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
QUESTIONS OR CONCERNS REGARDING PRIVACY
If you have any questions or concerns regarding privacy issues, please send us a detailed message to privacy@rationalinstinct.com and we will make every effort to resolve your concerns without delay.
You may also contact at:
Rational Instinct Ltd.
privacy@rationalinstinct.com
Alon 2 Tower, Tel Aviv, Igal Alon 94, Floor 31, Postal Code 6789139 WEBIZ-SMART BUSINESS OFFICES