Privacy Policy

Last Updated: May 24, 2018

The General Data Protection Regulation (GDPR) sets different provisions for users from the European Economic Area (EEA) than those from countries outside of it. While our Privacy Policy clearly distinguishes between those different groups of users, we treat all our users’ privacy with complete and equal seriousness, in compliance with applicable law.

When our widget is implemented on domains whose publishers are incorporated in the EEA, we treat all the users visiting this domain as if they were from the EEA.

European Economic Area (EEA) Users

We are Carambola Media Ltd, an Israeli company. Our principle place of business is at Hatidhar 17, Raanana, Israel.

As part of our operations, we deal with information relating to individuals. However, with the exception of email addresses you choose to give us through our website, we do not deal with any personal information of EU citizens at all: Not through our widgets and not through our website or in any other way.

If you choose to give us your email address through the form on our website, our Compliance Officer is responsible for how we use this limited personal information. They are Nadav Palmor, Product Manager, who can be contacted at contact@carambola.com. We use that email address to contact you and to provide you with information you have requested on our website - because it is in our legitimate interests to do so. We won’t use your email address for anything else and you can always ask us to delete it address at any time. Otherwise we will keep that email address for 1 year. Under certain circumstances, you have rights under data protection laws to do with the email address you have given us, as summarised below. You have the right to:

  • Request access to personal information we hold about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it – but, as we say, it’s just an email address you have provided to us.

  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal information. This enables you to ask us to delete or remove your email address where there is no good reason for us continuing to process it or where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal information where we are relying on a legitimate interest (of our own or of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your email address for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your email address in the following scenarios: (a) if you want us to establish the accuracy of it; (b) where our use of it is unlawful but you do not want us to erase it; (c) where you need us to hold it even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your email address but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your email address to you or to a third party. We can’t imagine you will ever want to use this but we are obliged to tell you about it.

If you wish to exercise any of the rights set out above, please contact us on the details above. We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. You will not have to pay a fee to access information we have about you (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive - alternatively, we may refuse to comply with your request in these circumstances. Also, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

If you feel that we have not handled information relating to you properly, or if you have contacted us about how we use that information and are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner’s Office online at ico.org.uk/concerns/

Users From Countries Which Are Not European Economic Area (EEA) Member Countries

Carambola Media Ltd. ( "Carambola" or "We") is committed to protect the privacy of persons who use, interact with, or access its services (as referred to in Our Terms and Conditions, defined below), via Carambola's website or websites of its customers (respectively, the "Users" and the "Customers", the Users and Customers may be referred to, jointly, as "you"). The use of, or interaction with, our services is governed by the privacy policy as detailed hereunder (the "Privacy Policy"). If You choose to use, interact with, register or submit information to our services as a User or Customer, You agree to the use of such data in accordance with this Privacy Policy. You may not use the Services or submit any information to Us if you do not agree to any of the terms hereunder. This Privacy Policy is an integral part of our Terms and Conditions attached to our Interactive Platform Agreement, (hereinafter, the "Terms & "Conditions") which establish, among other things, the use of our services, disclaimers, intellectual property rights, and limitations of liability governing the use of our services as described thereunder. This Privacy Policy shall not be construed in any manner to derogate from the Terms & Conditions or any other agreement made by and between Carambola and its customers (the "Customers").

Please note, that the services may contain links to other websites maintained by third parties, which may not be governed by this Privacy Policy. Furthermore, this Privacy Policy may not be applied to the practices of entities which are not controlled, owned, employed, or managed by Carambola, including the Customers and Users (as defined below), as well as any third parties to whom We may disclose Personal Information (as defined below) pursuant to the terms and conditions of this Privacy Policy.

Collection of Data

We receive and/or collect the following types of data and information about Customers, the Users:

  • We regularly receive and collect non-personally-identifying information from Customer's websites (desktop or mobile) ("Customer's Websites"). This sort of information may include, among other things, general, anonymous information about the Users, their use patterns within such Customer's Websites, whether or not directly related to such Users engagement with Carambola's services, , information about the device used by the Users (e.g., device type, operating system, browser type, language preference referring site). Such information will not identify a User personally.

  • We receive and collect non-personally-identifying information concerning use of our services by Users, such as how, what and when a User views or interacts with content and materials displayed by our services. For example, We may infer data from individuals' who replied and answered to the quizzes delivered by our service or the results thereof. We may also collect the Internet protocol (IP) address of those who use or interact with our services or our customers' services.

  • We also use cookies and local storage (small text files stored in a user's browser) or Web beacons (electronic images that allow to count visitors who have accessed a particular page and to access certain cookies) and other similar technologies to gather non-personally-identifying information. Users may at any time program their browser to block cookies, but should be aware that such blocking may prevent us from providing some or all of the services.

  • We may collect Personal Information that is specifically and voluntarily provided by the Users via our services or Users enter such information on our website (currently available at http://carambo.la/, and www.carambola.com). The term "Personal Information" when used in this Privacy Policy refers to personally identifiable information, such as name, date of birth, cell phone number, mailing and email address, company name, phone number, and so on.

  • Sometimes We receive data from our partners, publishers, advertisers, commercial customers and other third parties that help us (or them) deliver ads, understand the Users' or their users or anyone whom have interaction with our services in order to provide such entities with insights into what the Users or their users are interested in, maximize the effectiveness of ads, and generally make our services better.

Use of Data

We have developed a technology that uses the information and data collected from a page in order to identify the content on the Customers' Website, such as recognizing categories, segments, subjects, people, sports, teams and many other characteristics, in order to provide the Users, by a way of displaying to them on the Customers' Website, the most relevant tailored content from our library as well as relevant ads. For example, if a Customer's website has information or content about food and cooking, We may provide the Users who visit the Customer's Website with relevant recipes, cooking tips or information relating to nutrition. Alternatively, if we analyze to the information from answers received by a User who participated in a quiz that he/she is interested in rugby, we may provide him/her with information regarding MVPs, key figures in the field or upcoming matches. We may also display ads on Customer's Websites by Advertisers who engage us to display advertisements to individuals that, based on our analysis, are likely to have an affinity towards their products.

Furthermore, We may use and analyze the information regarding Users and use of our Services, for example traffic patterns, Users' demographics and behavior, in order to measure and understand the level of engagement our services generate, as well as the effectiveness of a certain ad and other content, for general business analytics and in order to provide for a more personalized experience.

We may also use the information and data We collect for maintenance, operation, archives, and enhancement of our services, and for other administrative purposes or internal operations, such as communicating with the Users, data analysis, testing and research.

Personal Information is used only for limited purposes. We may use Personal Information to communicate with Customers and Users regarding customer service issues, account administration, billing information, or to provide updates with respect to material changes or additions to this Privacy Policy or our Terms & Conditions. We may use Personal Data to respond to questions or comments, help us improve our products and services and to help resolve any problems.

Carambola processes Personal Information on its servers in many countries around the world. Such information may be stored on any of our servers, at any location. If a User is accessing the Services from a country other than the country in which our server is located, the various communications will necessarily result in the transfer of information across international boundaries. By accessing and/or using the Services and communicating electronically with us, you consent to these transfers.

Disclosure of Information

Carambola does not share or distribute Personal Information with unrelated third parties, except that Carambola may share Personal Information with its affiliates, partners, and other trusted business and individuals that provide Carambola, or to which Carambola provides, with a variety of services, such as publishers and advertisers that work with Carambola, developers that create content for Carambola, and service providers who process such information for us, so they can help us provide and improve our services, all for so long as those parties agree to keep such information confidential.

We may share or transfer the information in our databases to comply with a legal requirement, for the administration of justice, to protect our vital interests, to protect the security or integrity of our databases, to take precautions against legal liability, to respond to a violation of the Terms and Conditions, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

Unless otherwise described in this Privacy Policy, we do not share, sell, rent, or trade any Personal Information of Users with third parties for their promotional commercial purposes.

Carambola may share or distribute any and all non-personal information with our affiliates, partners and advertisers and with unrelated third parties.

Carambola may publish or share with third parties aggregate information for the purpose of analysis and statistics. Such disclosure is done anonymously and is non-personally identifiable. For example, we may share information publicly to show trends about the general use of our services and the market.

Persons under 18

Our Services are general audience services. Our Services are not directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. We do not knowingly collect or solicit Personal Information from people under 18. If we become aware that a person under 18 has provided us with Personal Information, we will delete such information from our files.

How do We protect your Data

We take commercially reasonable security measures to protect Customers and Users' information against unauthorized access or unauthorized alteration, disclosure or destruction of data. We reserve the right to use or disclose Personal Information to law enforcement, regulatory or other government agencies, or third parties if we reasonably believe that use or disclosure is necessary to protect Carambola's rights and/or to comply with a judicial proceeding, court order, or a legal process.

Links to Other Web Sites

Our services may contain links to third parties websites, we are not responsible for the practices employed by websites linked to or from our services, nor the information or content contained therein. Any use of a link which leads from our services to another website or platform, our Privacy Policy is no longer in effect and such action is subject to that website's or platform's own rules and policies.

Changes to This Policy

This Privacy Policy may change from time to time. We will post any policy changes on this page. You are encouraged to check for the latest policy often. Each version of this Privacy Policy will be identified at the top of the page by its effective date.

Contacting Us

If you have any questions about this Privacy Policy or concerns about the way We process your Personal Information, please contact us by e-mailing us at contact@carambola.com