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Privacy policyUpdated March 16, 2022

Traffic Jam ltd. ("Company”, “we”, “us” or “our“) respects the privacy of its Clients or Visitors (as such terms shall be defined below). This privacy policy ("Privacy Policy") governs the privacy practices of the Company with respect to its Services and its website available at https://www.apptimizer.net/ (“website”) as required, under applicable law including, but not limited to, the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

This Privacy Policy applies to visitors who access its Website ("you" or "Visitors") or use its Services ("you" or "Client").

In the event you are our Client, the Privacy Policy forms an integral part of our Services' Terms and Conditions ("Terms").
Please review our Terms and Conditions.

If you are a resident of California and the CCPA applies to you, please review our Privacy Notice for California Residents to find out more about your privacy rights in your jurisdiction.

Policy updates We may update or amend this Privacy Policy, at our sole discretion and at any time. Such updates will be effective upon the publication of the revised Privacy Policy. The last revision will be reflected in the “Last Updated” heading above. In the event that we make any material amendments to this Privacy Policy we will make best efforts to provide you with applicable notification with respect to such amendments. Please review this Privacy Policy periodically to make sure you stay up to date on any and all amendments.

The types of data collected When you access and browse our website or use the Services in any manner, we collect certain types of data that can be classified as follows:

non-identifiable aggregated data ("Non-Personal Data"), for example technical information transmitted by the device you are using and certain aggregated data regarding your use of the website or Services.

individually identifiable information (“Personal Data”, or “Personal Information”, subject to applicable law definitions). This may include name, email address and online identifiers, as detailed in the table below.

As required under the GDPR, please see below explanation regarding our lawful basis for processing Personal Data:

When you sign up for our Services as a Customer, we will process the information you will provide for the purpose of performing our contract with you and provide you with the service you requested;

When you access and browse our website, we have a legitimate interest in processing data, or when needed, such as when we use cookies, we will obtain your prior consent.

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We will also process your Personal Data subject to obtaining your consent, where required under applicable law.

It is important to mention that the Company will not combine Personal Data you voluntarily provide with Non - Personal Data will collect. However, if we will combine these types of data, we will treat the combined data as Personal Data.

Please see the table which details the types of data collected while you browse our website or use the Services offered therein, as well as the purpose of collection and how we use it:

Types of dataPurpose of collection and how we use it

Clients and Account Details
If you wish to partner with us and be provided with our Services, you will be required to create a username and password and when you do so you will need to represent and warrant that you are responsible for maintaining the confidentiality of your information and password. You further will represent and warrant that you will not provide us with inaccurate, misleading or false information. During the registration you will be requested to provide your contact details such as your name, email address, phone number, company name payment details, and additional information provided by you in order to be provided with our Services.

In addition, we will provide our Customers with our newsletter or other marketing materials. If you wish to opt-out – you may easily unsubscribe by contacting us at Traffic Jam ltd., or by other means we will make available (e.g. “unsubscribe” link within the applicable email).
We will use this data to provide the Services and designate your account. Your contact details will be used in order to send you needed information related to our Services and our business engagement (e.g., send you a welcome message, notify you regarding any updates to our Services, send applicable invoices, etc.) and additional occasional communications and updates related to the Services, as well as provide you with tips related to our Services, and promotional and marketing emails.

Contact Details
If you voluntarily choose to contact us for any reason, including support or any questions you may have, through any means of communication available (i.e., online form, email, mail, etc.) we will collect and process the information you provide which may include your name and email address.
We will process your contact details as well as your contact history for the purpose of responding to your inquiries and provide you the service or support you have requested. In addition, we may store this information if we believe it is necessary under our legitimate interests, for example, in order to defend legal claims.

Internet Protocol Address (IP) and Technical Data
When you access our website and use the Services, we (directly or by our third part service providers) will collect your IP address. In addition, we may collect technical Non-Personal Data, including type of operating system, type of device, type of browser, language preference, time and date of accessing the website, click stream in the website, approximate geographical location, etc...
We use this data in order to maintain, support, improve, protect and manage our website and Services and for Security Proposes such as preventing and detecting fraud and abuse.

How the data is collectedThe data detailed above can be collected if you voluntarily provide it (meaning when you contact us), or, automatically, through the use if of certain tracking technologies, for example, through the use of cookies and pixels.

Cookies policyOur website includes tracking technologies such as cookies and pixels. These tracking technologies are used for the purpose of gathering some information automatically, by ourselves or by service providers on our behalf.

“Cookies” are small text files that are placed on your hard drive by a web server when you access our website or use the Services. Cookies are used for many purposes, and for example, for making the interaction between you and the Services quicker and easier, enabling automatic activation of certain features, efficient navigation, providing the website in an applicable language in accordance with your country, etc., as well as for remarketing purposes (as detailed below). You can find comprehensive information about cookies at www.allaboutcookies.org.

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 cookies by following the instructions in your device preferences. However, please note that if you choose to disable cookies, some features of our website may not operate properly and your online experience may be limited.

In addition to our cookies used to operating the website and track performance of our campaigns, we may permit third parties to use cookies or other tracking technologies, as follows:

Cookie categorySourcePrivacy policy / Opt out

Analytics and Performance-related cookieswww.Google.com

Google Analytics.

This cookie is placed in order to track and analyze the use of our Services, for internal purposes, and may include the collection of your IP. https://policies.google.com/technologies/partner-sites

https://tools.google.com/dlpage/gaoptout.

For additional information of our use of Google products click here.

Essential, Functionality, Operation and Security Cookieshttps://www.tawk.to/https://www.tawk.to/privacy-policy/

Essential, Functionality, Operation and Security Cookieshttps://www.sendlane.com/https://www.sendlane.com/privacy

Opt-out Please note that, 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. By following the instructions of your device preferences, and by adjusting the privacy and security settings of your web browser, you may remove cookies, however, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited.

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 also contact us (see our contact details below), and we will make efforts to assist you.

Sharing data with third parties We do not share any Personal Data collected from you with third parties except in the following events:

Authorized Disclosures: we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices;

Legal Requirement: We may share your information in this situation, only if we are required to do so in order to comply with any applicable law, regulation, legal process or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);

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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 us, our clients or any applicable third party;

Affiliated Companies and Corporate Transactions: We may share your information with our parent company, any of our subsidiaries, joint ventures, or other companies that are under common control with the Company (“Affiliated Companies”) solely if and when applicable or necessary for the purposes described in this Policy, as well as 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, we will make our best efforts to ensure that our Affiliated Companies or acquiring company assumes the rights and obligations as described in this Policy.

Service Providers and Business Partners: We may share your information with third parties that perform services on our behalf (e.g., analytic services).

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other clients) to third parties.

Your rights We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Data, according to applicable data protection and privacy laws.

Privacy laws differ from jurisdiction to jurisdiction, each of which may provide you with different rights regarding your Personal Data. The following are some of the rights that you may be able to exercise depending on the applicable data protection laws that apply to you.

The right to be informed – you have the right to be provided with information regarding our data collection and privacy practices, as described in this Privacy Policy.

The right to access your Personal Data - you have the right to request confirmation that we process your Personal Data, and under some circumstances, be provided with a copy of your Personal Data that we process.

The right to be forgotten - you have the right to require the erasure of certain Personal Data, if specific conditions are satisfied (if the Personal Data is no longer needed for the original purpose that it was collected for and there is no new lawful basis for continued processing); if you exercised your right to withdraw consent (if applicable), or to object to the processing and we have no overriding grounds for continuing to process the Personal Data; the Personal Data is processed unlawfully; or the erasure of the Personal Data is necessary in order to comply with applicable legislation. Please note, that this right is not absolute. We may not accept a request under certain circumstances, for example if we need to retain the applicable Personal Data in order to comply with our legal obligations or defend against legal claims, etc.

The right to object to the processing of your Personal Data - you have the right to object to our processing of your Personal Data, in the event the legal basis for processing is our legitimate interests. Notwithstanding the above, we will be permitted to continue the processing of such Personal Data if our legitimate interests override your rights, or when the processing is necessary to establish, exercise or defend a legal claim, etc.

The right to restrict processing - you may be entitled to limit the purposes for which we process your Personal Data. This right is applicable when: the accuracy of the Personal Data is contested; the processing of the Personal Data is unlawful and you request restriction instead of erasure; the Personal Data is no longer needed for the original purpose it was collected, however it is still required to establish, exercise or defend legal rights; or there are overriding grounds in the context of an erasure request;

Rectification - you have the right to require an entity that is processing your Personal Data to update your Personal Data that is not correct;

Data Portability - you have the right to have your Personal Data "ported" to a third-party;

File a complaint - You may also be entitled to file a complaint with the appropriate supervisory authority in connection with any concerns you may have with regards to your privacy.

if you wish to submit a request to exercise any of the above rights, please send it to our privacy team at: [email protected]. Please note that, we may require additional information from you in order to verify your identity and locate your information. This may take some time, subject to applicable law. If we require more time, we will inform you in writing of the reason for the required extension and the length of time the extension will be. Additionally, you have the right to contact your local data protection authority, at any time. If we cannot fulfill a request we will explain our reasons why we cannot do so in the response to such request. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Please note that the data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you.

Data retentionWe retain the Personal Data we collect for as long as needed to provide the Service, carry out our business purpose, perform our contract with you, and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed above. We are entitled to rectify, replenish or remove incomplete or inaccurate information, at any time and at our sole discretion.

Security We use physical, technical and administrative security measures to protect Personal Data, that we believe are in compliance with applicable laws and industry standards in order to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost.

If you feel that your privacy was treated, or if suffered from an attempt to abuse our website or Service, please contact us directly at: [email protected]. 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.

Children You represent and warrant that: (i) You are above the age of 18; and (ii) you are of legal competence to enter into this Policy. The Service and our website are not directed or intended for individuals under the age of 18 and we do not knowingly collect or solicit information from them. If we obtain actual knowledge that a client is under 18, we will take steps to immediately delete such client’s Personal Data. If you become aware or have any reason to believe that an individual that is under the age of 18 has shared any information with us, please contact us at [email protected].

Transfer of your data We may store or process your information in the Brazil, Brazil, Brazil, Brazil and Brazil or in other countries. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your information 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 data requires your consent, then your consent to this Policy includes your express consent for such transfer of your Personal Data.