Privacy Policy

[Last Revised: November 5 2018]

Kashcow Ltd (“Company”, “we”, “us” or “our”) provides you with various content websites. This privacy policy (“Privacy Policy”) is an integrated part of our Terms and Conditions (“Terms”). Definitions herein shall have the meaning assigned to them in the Terms. This Privacy Policy governs the privacy practices of the Company and applies to users that access our websites or use our Services. This Privacy Policy provides important and transparent disclosures on how or why we collect, share and use our users’ data:

• If you sign up for any of our Services, we process your personal data in order to perform our contract with you; this equates to a legitimate reason to obtain and utilise your data
• If you sign up for any of our Services, we may use your data for online identifiers when you access our website in order to improve user experience and assist us in website maintenance
• We will only process your personal data to the extent necessary for the performance of our service(s) and we will only use your personal data for direct marketing where you have provided us with consent to do so

We want to enable you to make an informed decision about your use our Services and so we encourage you to read this Privacy Policy carefully.

If you have any questions about this Privacy Policy, please contact us at: hello@kashcow.net (or as described below).

Data Collected and Purpose of Use

Depending on your interaction with our Services, we may collect two types of data you, as follows:

• Non-identifiable information which may be made available or gathered through your use of the Services. To clarify, we are not aware of your identity due to such information (“Non-Personal Data”)
• Individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”)

In addition, if we combine Personal Data with Non-Personal Data, the combined data will be treated as Personal Data for as long as it remains combined.

The table below details the types of data we collect and how we use it:

What type of data we collect?	How do we use it?
In some cases, we may collect technical and aggregated data about you that is considered as Non-Personal Data, and may be made available or gathered via the users’ use of the website, including: type of browsers; type of operation system; type of device; time and date you access the website and use the Services; users’ navigation and actions in the website; language preference; country level location	We use this data solely to provide and enhance our Services and to enable operation of the website
If you voluntarily contact us whether through the “Contact Us” page in the website, by sending us an email, or any other request or notification, you may be required to provide us with certain information such as your name and email address	We will use this data solely to provide you with the support you have requested or response to your inquiry
If you voluntarily subscribe to our newsletter you will be asked to provide us with your name and email address. You can unsubscribe at any moment through the “unsubscribe” link within the emails we send from time to time or by contacting us directly	We will use this information solely to provide you with the content you have requested to extent permitted by your consent
If you voluntarily leave a comment on the website or submit a review you will be asked to provide us with your name and email address. If we will decide to post your comment, it will be posted under the name you have provided. In addition, we may send you an email notifying you other users have responded to your comment or review	We will use this information solely upload your comment, send you update regarding users’ feedback and for validation
We will collect your Internet Protocol (“IP”) addresses. Note that while IP address is considered personally identifiable information in many jurisdictions (such as the EEA), there are some jurisdictions in which such data sets are not considered as Personal Data. However, we treat such information as Personal Data, in accordance with applicable laws	We use the IP in order to fulfill our legitimate interests to: maintain, protect and manage the website and Services; customise and improve our Service, as well as enhance your experience while you use our Services; in order to perform research, analytic and statistic regarding traffic flow and users’ interaction with our Services; in order to audit our affiliates, calculate payments and detect fraud, as well as detect and resolve security or technical issues in connection with the Services; We also use IPs for remarketing purposes, as detailed in the “Cookies” section below.

How We Collect the Data

We may collect the above detailed data from you, in the following manners:

• Automatically, including through the use of cookies (as elaborated in the “Cookies” section below), and other similar tracking technologies when you interact with our website and Services; or
• When you voluntarily choose to provide us with information, i.e. when you contact us, register to our Newsletter, etc. Whenever technically possible and required under applicable law, we will ask for your consent to collect your Personal Data and offer you the choice to opt-out.

Cookies

When you access the website or use the Services, we may use “cookies” (or similar tracking technologies). The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help customise your experience. You can find more information about cookies at: www.allaboutcookies.org.

There are several types of cookies, and among others:

• Essential, Functionality, Operation & Security Cookies. These cookies are essential for enabling user movement around the website, for the website to function properly and for security purposes (i.e. used to authenticate users, prevent fraudulent use and protect user data from unauthorised parties). This category of cookies either cannot be disabled, or if disabled, certain features of the Services may not work
• Analytic, Measurement & 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 Content and campaigns. These cookies enable us, for example, to assess the number of users who have viewed a certain piece of content as well as their country of origin. It enables our websites to remember information that changes the way it behaves or looks, such as your preferred language. Further, it provides us the ability to know if such content is popular and to provide content of similar topics for our users. We further use this information to compile reports
• 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 (e.g. the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage)

Cookie	Purpose	Privacy Policy & Opt-Out
Google HSID, SID, SIDCC	Security	https://policies.google.com/privacyhttps://policies.google.com/technologies/managing?hl=en
Google (AdWords, DoubleClick) APISID, SAPISID, SSID, HSID, SID, PREF, IDE, NID, 1P_JAR.	Preference,  Targeting & Advertising	https://policies.google.com/privacyhttps://policies.google.com/technologies/managing?hl=en
Google Analytics _ga  _gid  _gat_UA _gaexp	Analytic,  Measurement & Performance	http://www.google.com/intl/en/policies/privacy/https://tools.google.com/dlpage/gaoptout
Bing MR, MUID	Analytic,  Preference,  Targeting & Advertising	https://privacy.microsoft.com/en-us/privacystatement
Facebook  fr	Analytic,  Measurement,  Targeting & Advertising	https://www.facebook.com/policies/cookies/
YouTube GPS, IDE, PREF, VISITOR_INFO1_LIVE, YSC		http://www.google.com/intl/en/policies/privacy/https://tools.google.com/dlpage/gaoptout
New Relic JSESSIONID	Analytic,  Measurement,  Performance & Preference	https://docs.newrelic.com/docs/browser/new-relic-browser/page-load-timing-resources/new-relic-cookies-used-browserhttps://newrelic.com/termsandconditions/cookie-policy
Hotjar _hjIncludedInSample  ajs_anonymous_id	Analytic,  Measurement,  Performance & Preference	https://www.hotjar.com/legal/policies/cookie-informationhttps://www.hotjar.com/legal/policies/privacy/https://www.hotjar.com/legal/compliance/opt-out
Hubspot hubspotutk  __hstc  __hssrc  __hssc	Analytic,  Measurement,  Performance & Preference	https://legal.hubspot.com/privacy-policyhttps://knowledge.hubspot.com/articles/kcs_article/reports/what-cookies-does-hubspot-set-in-a-visitor-s-browser
MixPanel mp_6d7c50ad560e01715a871a117a2fbd90_mixpanel  mp_34b2c3939599013bd0c86fabf1ed8c70_mixpanel	Analytic,  Measurement,  Performance & Preference	https://mixpanel.com/legal/privacy-policy/
Adoric adoric_goals  adoric_uniq_day_id  adoric_user	Functionality	https://adoric.com/privacy
Cloudflare __cfduid	Security & Functionality	https://www.cloudflare.com/privacypolicy/
Proonto – Chat Provider ADS_TOKEN  prt_uniqueId  prt_companyId  prt_clientId  prt_clientName  name_10001361  clientId_10001361  uniqueId	Operation & Functionality	https://proonto.com/privacy-policy/
MaxMind	Operation (GEO Location Services)	https://www.maxmind.com/en/privacy_policy
TrafficPoint VIEWER_ID  nf_wp_session  snp_snppopup-exit  ADS_TOKEN	Operation & Functionality

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies or receive a warning before a cookie is stored. You may remove our cookie by following the instructions of your device preferences. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited. Please see opt-out information under the “User Rights & Control” Section below.

Third Party Content

Our Website may link to third party landing pages, registration pages or websites, whose privacy practices may differ from ours. Please note that we are not responsible for the privacy practices of any such third parties and we cannot control the privacy practices enacted by such third parties. Once you leave our website via a link, you should check the applicable privacy policy of the third party. Your information is governed by their privacy statements.

Sharing Data with Third Parties

We will not share your Personal Data with third parties, outside as specifically mentioned herein: (i) user’s explicit consent – we may disclose your Personal Data to third parties upon your explicit consent. Please note that once we share your information with third party, that information becomes subject to the other third party’s privacy practices; (ii) policy enforcement – we may disclose or share your Personal Data, solely to the extent needed to enforce our policies (including our policies and agreements) and to establish or exercise our rights to defend against legal claims, as well as investigations of potential violations thereof, including without limitations, investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud, security or technical issues; (iii) third party rights – we may share your information in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of our users or any applicable third party; (iv) law enforcement – we may disclose or share your Personal Data, solely to the extent needed 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.); (v) affiliate company and corporate transaction – we may disclose or share your Personal Data with our parent company (should we come under ownership of one), any subsidiaries, joint ventures or other companies under common control (“Affiliated Companies”) solely if and when applicable or necessary for the purposes described in this Privacy Policy or 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, our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Policy; (vi) identifiers – we may disclose or share online identifiers collected by us (e.g. IP), for the purpose of operating our business and providing the Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the Service; (vii) Service Providers – we may disclose Personal Data to our service providers to perform requested services on our behalf. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services (e.g. email marketing services).

Notwithstanding the above, may share aggregate or Non-Personal Data with our business partners and other third parties in any of the above circumstances, as well as for any business operation and commercial use.

How Long We Retain the Data We Collect For

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. We retain the data we have collected for as long as needed to provide the Service, carry out our business purpose and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws or until an individual requests us to delete their Personal Data, as detailed below.

Users’ Rights & Controls

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 Data. 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. We are permitted to ask that an individual making such a request provides us with reasonable confirmation of certain details so that we can have confidence that they are the person that the data relates to, to prevent us sharing information with parties who have no rights to their details.

The principal rights under applicable data protection law in relation to Personal Data are as follows (depending on your jurisdiction): the right to access any information which is provided to us; the right to rectification; the right to erasure; the right to restrict processing; the right to object to processing; the right to data portability; the right to complain to a supervisory authority (in the event you are EEA resident); and the right to withdraw consent (to the extent applicable).

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data, depending on your relationship with us. If you wish to exercise any or all of the above rights, please contact us here and provide information regarding the rights you wish to exercise: hello@kashcow.net

Where we are not able to provide you with the information which you have asked for, we will endeavour to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisory authority (in the event you are EEA resident). As mentioned above, we reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

Opt-Out right

You may opt-out of the data collection, sharing process and advertising services related to our website, as follows:

• You may set your browser to block all cookies, including cookies associated with our Services or to indicate when a cookie is being set, by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful: Google Chrome; FireFox; Internet Explorer; Safari; Edge; Opera
• You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services like 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 these services may be limited according to your geographic location and jurisdiction
• You may contact us (as detailed below), and we will make best efforts to assist you;

Note that once you 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.

Security of the Data

We take great care in implementing and maintaining the security of the website or Service and your Personal Data. We employ industry standard procedures and policies and maintain technical and administrative security measures to ensure the safety of our users’ Personal Data and prevent unauthorised access or use of any such information. However, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure and we cannot be responsible for the acts of those who gain unauthorised access or abuse our website or Service and we make no warranty, express, implied or otherwise, that we can guarantee to prevent such access.

We adopt what we believe are appropriate data collection, storage and processing practices and security measures to protect against unauthorised access to such data and according to applicable law requirements.

Children Privacy and Data

The Services are not intended for individuals under the age of eighteen (18), Accordingly, we do not use the website to knowingly solicit data from or market to children as defined under applicable law (e.g. thirteen (13) regarding US individuals and sixteen (16) regarding European Economic Area (“EEA”) individuals). We request that such individuals do not provide Personal Data through our Services. We reserve the right to request proof of age at any stage so that we can verify that children under the age of eighteen (18) are not using the website. If you become aware or have any reason to believe that a child has shared any information with us, please contact us at hello@kashcow.net and we will take reasonable steps to ensure that such information is deleted from our files.

Transfer of Data

We may store or process your Personal Data in the EEA or in other countries. If you visit our website or use our Services from locations outside of the EEA, please note that any information you provide to us through your use of our website or Service may be transferred to and processed in countries other than the country from which you accessed our website. 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 upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your use of our Services is construed as your consent to this Privacy Policy and by extension this includes your express consent for such transfer of your data.

Do Not Track Disclosure

The website or our Services do not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

Amendments

We reserve the right to amend or revise this Privacy Policy from time to time, at our sole discretion, so please re-visit this page frequently. Any changes to this Privacy Policy will become effective immediately upon the display of the revised version. The most recent version of the Privacy Policy will always be posted. If we do make any changes, the updated date at the top of the Privacy Policy will be reflected in the “Last Revised” heading. Your continued use of the website or our Services, following the display of such modified Privacy Policy, constitutes your acknowledgement and consent of such amendments and your agreement to be bound by the terms of such amendments. In the event of a material change we will make best efforts to provide a written notification.

Further Questions?

If you have any questions about this Privacy Policy, please contact us at: hello@kashcow.net

Company’s Data Protection Officer:

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the Personal Data, please contact our Data Protection Officer at: hello@kashcow.net

Please include your name, address and email address in any correspondence so that we can respond to your enquiry or request.