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Tok Media Privacy Policy

Last Revised: January 7, 2015

Tok Media International Ltd. and its affiliates (“Company” "us" or “we”) respect the privacy of its users (“User” or “you”) and are committed to protect the User's information. We believe that you have a right to know our practices regarding the information we may collect and use when you visit or use our proprietary online website available at: http://toksnn.com/ (the “Site”) and our proprietary online platform ("Platform") which enables you to view, link to and/or participate in certain polls, surveys discussions on news articles available on and/or incorporated into through third-party social publishers platforms (e.g., Facebook) and/or certain third party partner websites (e.g., New York Times, Huffington Post, and other such news and article-based websites etc.) (collectively, the “Publishers Websites”).

1. Your consent (important, please read carefully!)

By entering into, connecting, accessing and/or using the Platform and/or the Publishers Websites and/or the Site, you agree to the terms and conditions set forth in this Privacy Policy, including to the collection and processing of your Personal Information (as defined below).PLEASE NOTE: IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE PLATFORM, THE PRODUCT ON THE PUBLISHERS WEBSITES AND THE SITE.

2. Which information we may collect on our Users?

We may collect several types of data and information from our Users:

Non-personal Information :

The first type is non-identifiable and anonymous information. We have no idea what is the identity of the User from which we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while the User is entering, connecting to, accessing or using the Site, the Publishers Websites and/or the Platform. Non-personal Information which is being gathered consists of technical information and behavioral information, as detailed below:

Technical information :

  • Type of operation system (e.g. Windows, Linux, etc.)
  • Type of Browser (e.g. Explorer, Firefox, Chrome, Safari, etc.)
  • Screen resolution (e.g. 800x600, 1024x768, etc.)
  • Browser and keyboard language (e.g. English)
  • Flash version.
  • You computer’s configurations and settings and any similar technical data and information.

Behavioral information :

  • User's click-stream on the Platform and/or Site (i.e. the fact that User has chosen to click on a certain link or access a certain feature in the Platform and/or Site).
  • The activities of the User on the Platform and/or Site, including information pertaining to discussions participated or read by the User (e.g. which discussions posted, read, commented etc.).
  • User's behavior on our Facebook application (e.g. discussions you have posted, shared, commented on, followed, last login date etc.).
  • Any similar behavioral information.

Please note that by using our Platform via Publishers Websites you hereby agree to the aggregation of behavioral data for the purposes of using such data for behavioral targeting of advertisers on third party websites.

Personal Information :

The other type of information we may collect is individually identifiable information. This information may identify an individual and may be of a private and/or sensitive nature such as name and address. Personal Information which is being gathered consists of the User's IP address and any other personal details provided voluntarily by the User during registration to the Site or using the Platform, either directly or via certain service providers (e.g. Facebook) which use Single Sign-On mechanisms (as shall be further explained below) and/or via Publishers Websites.

Information from Facebook :

In the event that a User uses the "Log in with Facebook" feature (which functionality is described in the Terms) then Facebook provides us with access to certain information about such User as is stored in the User’s Facebook account, namely, the User's public profile (i.e., User's name, profile picture, email address, gender and other public information) and his/her list of friends and/or any other information which is detailed and displayed to the User in the notice which appears during the "Log in with Facebook" process. Please read carefully such notice in order to understand what information is available to the Company via Facebook. We may collect your login information and other relevant information necessary to enable us to access your Facebook account (such as, Facebook UserID, User access token) in order to collect and/or store, to the extent legally permissible, the abovementioned data contained within your Facebook account (or any part of it). In the event that the User uses the "Log in with Facebook" feature, then such User agrees that we may share his/her name and/or profile picture on the Site. If you do not agree to these practices please do not use the “Log in with Facebook” feature on our Site.

Please note : Publishers Websites using Single Sign-On mechanisms may share with us certain information about you such as your name, nickname, profile picture file or URL, and contact details. Such information is shared with us for your convenience, in order to enable you to access the Platform after signing-in the Publisher Website, and without the need to register to the Platform separately.

Information from Publishers Websites :

When we collect information voluntarily provided by you via third-party Publishers Websites, we may aggregate such information including but not limited to posts and/or comments and/or contributions to discussions and/or votes on polls (“Comments”) published by users on Publishers Websites (“ Commentators”) on the particular Article aggregated by us. We may also collect the user name and such other information as voluntarily provided by the Commentators for public display on Publishers Websites through our Platform.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval. Your approval is obtained (i) through your acceptance to the Terms and the Privacy Policy; and/or (ii) when you accept the privacy policy and terms of use of the Publishers Websites.

3. How do we collect information on our Users?

There are two main methods we use:

  1. We collect information while you access or use the Site, the Publishers Websites and/or Platform. In other words, when you access or use the Site, the Publishers Websites and/or Platform we are aware of your usage of the Site the Publishers Websites and/or Platform, and may gather, collect and record the information relating to such usage. For example, when you connect to the Platform, available on the Site and/or at the Publisher Website, your computer tells us your IP address. We may further log the content you generate and/or aggregate and/or link to during your use of the Platform and/or Site.
  2. We collect information which you voluntarily provide us, whether during registration to the Site or using the Platform via certain service providers including but not limited to via Publishers Websites. For example, when you wish to connect to the Platform for the first time through Facebook, we will ask you to allow Facebook to provide us certain information (as described above).

4. What are the purposes of the collection of information?

Non-personal Information is collected in order to :

  • Use it for statistical, analytical and research purposes and for customization, development and improvement of our Site and/or Platform
  • Enhance the User's experience on the Site and/or Platform (e.g. by determining the screen resolutions).
  • Learn about the preferences of Users and general trends on the Platform (e.g. understand which features are more popular than others).

Personal Information is collected in order to :

  • Enable the overall operation of the Platform and/or Site.
  • Personalize your experience on the Platform and/or Site.
  • Provide you with certain information and services available only to registered Users.
  • Allow us and our partners to contact you with proposals and tailored information regarding events, offers, services, etc.
  • Publicly identify Commentators with their respective Comments on a particular Article.
  • Identify you when conducting customer service operations (such as providing feedback, etc.).
  • Analyze discussions based on non-nominal aggregated demographic and other data.

5. Anonymous Use of the Platform

While we may collect any of the Non-personal Information and/or Personal Information about you and your use of the Platform, you may use the Platform and/or participate in the polls and/or discussions about Articles as an anonymous user. This means that your name and Account information will not be made available to the public. However, as an anonymous user, your contributions to discussions and polls will be made available to the public. Your activity will be under an anonymous screen name automatically assigned to you (that can later be changed). You may post a specific comment on or via the Platform as an anonymous user and/or become a permanent anonymous User by checking clicking on your Account Settings menu and then select the “Post Anonymously” User” option checkbox. Only new Comments you make will appear under your anonymous screen name. Previous Comments made by you on or through the Platform (if any) will continue to be attributed to your account.

We will remove your Personal Information from our servers within a reasonable period of time following your removal the application from your Facebook account (see Section 9 below) and in accordance with our policies and applicable law. Once deleted from our Servers, our Partners will not be able to link to any of your Personal Information on our Servers and your Comments will be identified under an “Anonymous User” tag or the like (meaning that it will not link back to your Facebook Account).

Please note that while you may use the Site anonymously; we retain certain Personal Information about you on our servers. You may not abuse this feature or use it in violation of any of the Terms, including without limitation stalking, harassing or otherwise infringe the privacy of other users, posting liable, defamatory, profanity and/or obscene content. Any violation of the Terms, even as an anonymous user, may lead to sanctions on your Account including removal of your Account, which will block you from using the Platform altogether.

If you have encountered a User, even an anonymous User, who you feel has violated the Terms, please report to us and we will use our best efforts to review your report and take at our sole discretion, necessary actions as we deem appropriate within a reasonable period of time.

6. Personal Information that is viewable to persons outside of the Platform

In order to enhance Users experience with the Platform, we make our Platform available through different Publishers Websites (for instance embedding relevant discussion groups and polls within a Publisher's Website).

Please note, when you participate in a discussion group or answer a poll that is also embedded in a Publisher's Website, your Personal Information (such as name, profile picture and comment) is viewable by any person currently using the Publisher's Website. Should you wish to avoid your personal information from viewed by people using the Publisher Website, you may use the "Post Anonymous" option (for further information see section 5 above).

7. Sharing Personal Information with Third Parties

The Company will not share any Personal Information it collects with any third party. Notwithstanding, we may share Personal Information in the following cases:

(a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy or the Terms of use, including an investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to claims that any content published on the Platform violates any right or endangers the safety of any third-party; (e) to protect the rights, property, or personal safety of the Company, its Users or the general public; (f) when Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company; (g) to embed the Platform and share Commentators’ and/or your information (such as Comments) from time to time in any Publisher’s Website for the purpose of enabling the provision of the Platform from within such Publisher’s Website and/or service subject to your Account privacy settings on the Platform, as of the applicable update date; (h) to collect, hold and/or manage your Personal Information through the Company's authorized third parties service providers (including, as applicable, their affiliates as necessary to provide us with the requested services) as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (i) pursuant to your explicit approval prior to the disclosure; (j) to respond to User's support requests; or (k)cooperate with third parties for the purpose of enhancing the User's experience.

For avoidance of doubt, the Company may transfer and disclose Non-personal Information to third parties at its own discretion.

8. Direct Marketing & Advertising

Direct Marketing : You hereby agree that we and our partners we may use your contact details for the purpose of informing you regarding products and services (offered by the Company and/or by third parties) which may interest you and send you advertisements and other marketing material, transmitted via the e-mail address you have provided.

The foregoing consent constitutes consent to transmission of advertisements pursuant to the Telecommunication Law (Bezeq and Transmissions) (Amendment No. 40), 2008 and any similar provision under any applicable law. You may withdraw your consent via written notice to the Company or on the same manner as the advertising was transmitted to you. It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable in connection thereof.

Advertisements : We accept advertisements from third party advertisers on our Site and through our Platform on Publisher's Websites. These advertisements are intended to provide information about products and services that we think may be of interest to our Users. Note that if you click on any of these advertisements, these advertisers may use cookies and other web-tracking technologies to collect non-personal and/or personal information about you. We recommend that you review the terms of use and privacy policy for any advertiser who you are interacting with before doing so. Their privacy policy, not ours, will apply to any of those interactions.

All the information contained in such advertisements and commercials belongs solely to the advertisers and the Company makes no warranties or representations in respect of such, whether or not the Company has control over such advertisements or commercials and these are provided on an "AS IS" basis. In any event, the Company will not be liable for any damage or loss incurred to you as a result of or in connection with such advertisements or commercials. The Company, advertisers and/or related third-parties may be entitled to certain shares of the earnings for such advertisements and/or commercials. You agree, acknowledge and consent that no right, title or interest is or shall be granted to you in any way with respect to any revenue share whatsoever in relation thereto.

9. Modifications or Deletion of Personal Information

If for any reason you wish to delete your Personal Information and/or Comments on the Platform, you may do so in the following manners:

If you are logged on to the Platform via Facebook, by accessing your Facebook account and click on the “Privacy Settings” and/or “Apps and Websites” menu, “Apps you use”, “Apps dashboard” and then on the “Remove app” option.

If for any reason you wish to delete or modify your Personal Information made available to us through Publishers Websites please contact the owner of the Publishers Website through which you are using the Platform. Your request will be handled by the owner of such Publishers Website and/or to the extent applicable, such request will be transferred to us by that owner. Reasonable efforts will be made to modify or delete any such Personal Information pursuant to any applicable privacy laws. Aggregated and/or anonymous data may remain on our servers indefinitely. Note that unless requested otherwise, we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws

If for any reason you wish to delete your Comments from the Site (either entirely or just some), you need to specifically request that the Company do so via e-mail to the following address: updates@tok-media.com.

10. Minors

The Platform and/or Site are intended for Users over the age of thirteen (13). Therefore, the Company does not intend and does not knowingly collect Personal Information from children under the age of thirteen (13) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of thirteen (13) are not using the Platform and/or the Site. If we learn that we collected Personal Information from children under the age of thirteen (13) we will delete that information as quickly as possible. Please contact us at updates@tok-media.com if you have reasons to suspect that we collected Personal Information from children under the age of thirteen (13) and we will delete that information as quickly as possible.

11. Cookies & Local Storage

When you access or use the Site and/or Platform, Company may use industry-wide technologies such as “cookies” and Flash (or similar technologies), which stores certain information on your computer (“Local Storage”) and which will allow us to enable automatic activation of certain features, and make your Platform and/or Site experience much more convenient and effortless. The cookies used by the Platform and/or Site are created per session, does not include any information about you, other than your session key and are removed as your session ends (usually after 24 hours). It is easy to prohibit the Local Storage. 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. In order to erase or disable the Local Storage option in Flash you should use the settings option of Flash according to the specific instructions provided by the technology provider. However, if you block or erase cookies, or change the settings of Flash, your online experience may be limited.

We also use certain third-party cookies. These are a different kind of cookies, stored on your computer by third parties, rather than by the Company. This kind of cookie is only read (and not altered by the Platform and/or Site) each time you visit the Platform and/or Site, and also when you visit certain websites or applications that uses similar cookies. Third-party cookies usually store only a Non-personal Information, such as the web pages you have visited, the duration of your browsing, etc.

12. Security

We take a great care in maintaining the security of the Platform and/or Site as well as your information and in preventing unauthorized access to it through industry standard technologies and internal procedures, including through the use of tokens and encryption mechanisms. However, we do not guarantee that unauthorized access will never occur.

13. Links to Third Party Websites

While using the Platform on the Site and/or on the Publisher’s Websites you may encounter links to third party websites. Please be advised that such third party websites are independent from the Platform and/or Site, and we assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites. Your access to, use of and reliance upon any such sites, services and content and your dealings with such third parties are at your sole risk and expense. The Company reserves the right to terminate any link at any time. We encourage you to carefully read the privacy policies and the terms of use of such websites.

14. Third Party Software/Service

While using the Platform on the Site we may be using third party software and/or service, in order to collect and/or process the information detailed herein. Such software include without limitation, Google Analytics, which privacy policy is available at http://www.google.com/intl/en/policies/privacy/ , Amazon’s Platform, which privacy policy is available at http://aws.amazon.com/privacy and Kontagent’s Platform, which privacy policy is available at http://www.kontagent.com/privacy-policy.

15. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Platform and/or the Site and any information collected therein. Company reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Site. Such material changes will take effect seven (7) days after such note was provided on our Site. All other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site and/or Platform after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

16. Got any Questions ?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcomed to send us an email to the following address: updates@tok-media.com and we will make an effort to reply within a reasonable timeframe.