At Olibra LLC (the “Company” or “we”), we recognize that privacy is important. This policy applies to all of the software, services, information, tools, features and functionality offered by the Company and/or its subsidiaries and/or affiliated companies on our proprietary application known as “Bond” and its website available at: olibra.io (collectively, the “Services”) and covers how PII that the Company collects and receives, including in respect of any use of the Services, is treated. If you have any questions about this policy, please feel free to contact us [email protected]
1. Information We Collect and How We Use It
Unless stated otherwise in this policy, the Company will not share, sell, auction off or give away your PII to any third-party or other organization without first obtaining your prior written consent. In order to provide our Services, we may collect the following types of information:
- Information you provide. For some features of the Services we ask you for PII, including, but not limited to: name, email address, telephone number. As part of the Services, we may collect any PII that you post and/or upload and/or transmit through the Services, including, but not limited to, any photos scanned using the Services and any details that you provide relating to such photos, such as the names of the people (including people-tagging) in the scanned photos and where the photo is taken.
- Personal information. We process your PII only for specific and limited purposes, including the provision of the Services. We ask only for PII that is adequate, relevant and not excessive for those purposes. Some of these purposes may include to inform you of new services and features we will be providing, to send you requested information and additional materials in respect of the Services, for promotional purposes, and internally to help us improve our Services and to help resolve any problems.
- User information. When you use the Services, we may automatically receive and record information from your device, documents and browser, including your IP address, cookie information, your regional and language settings, device model, operating system, the physical location of your device along with GeoTaggings (if you have permitted your mobile or other location-aware device to transmit location data), and software and hardware attributes. We may use your location (city) (if you have permitted your mobile or other location-aware device to transmit location data) to learn how to adjust and personalize your use of the Services. Our systems may automatically record and store technical information regarding the method and nature of your use of the Services, including, without limitation, the date on which you registered to the Services, which pages or widgets of the Services our visitors view and the dates and times on which they viewed such pages or widgets, impressions, the number of views they get and any actions they make in the Services (such as when a photo was scanned, edited, or deleted, when a photo was shared and with whom, or metadata relating to photos tagged by you (e.g. captions, dates, people-tagging ). We use your IP address to help with server problem diagnosis and to administer the Services. An IP address is a numeric code that identifies your device on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups to determine which domain you are coming from (i.e: aol.com, yourcompany.com) to more accurately gauge our users’ demographics.
- Traffic data collected through the Services. In addition to the information we collect as described above, we may use technology to collect information about the use of the Services. For example, our systems may automatically record and store browser information, search history, exit point, use time, platform type, operating system information, number of clicks and cookies. This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of the Services. The Services contain hyperlinks to other pages, widgets and features on the Services. We may use technology to track how often these links are used and which pages, widgets and features of the Services our visitors choose to view. Again this technology does not identify you personally it simply enables us to compile statistics about the use of these hyperlinks.
- Cookies. In order to personalize your experience and collect and analyze the anonymous data described herein, we may use temporary cookies that remain on your device for a limited period of time. We may also use persistent cookies that remain on your device until the application is removed, in order to record any content you may have gained access to by using Services. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your device. Cookies do not damage your device. Most browsers or devices may allow you to block cookies but you may not be able to use some features on the Services if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not). We may also use web beacons via the Services to collect information. Web beacons or “gifs”, are electronic images that may be used in our Services or in our emails. We may use web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.
- User communications. When you send email or other communication to the Company, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. We may send you push notifications to send you special updates in respect of the Services. You should be able to opt-out of these notifications at the device level. We may also send you newsletters and promotional communications if you joined our mailing list, you may opt-out of this service at any time by submitting a request [email protected]
- Children. We care about the safety of children. Because the Services are not directed towards children under 18, they are not allowed to register with or use the Services, or provide PII. If you are under the age of 18 or the age of legal majority where you reside if that jurisdiction has an older age of majority, you must obtain parental consent (or consent from your legal guardian) prior to using our Services. We do not knowingly contact or engage with children under the age of 18 (or the age of legal majority where you reside if that jurisdiction has an older age of majority) without said parental consent (or consent from your legal guardian). If you have reason to believe that a child under the said age has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases.
- Maintenance. The Company uses the PII that you provide or that we collect to operate, maintain, enhance, and provide the Services.
- Analysis. The Company uses all of the PII that we collect to understand the usage trends and preferences of our users, to improve the way the Services work and look, and to create new features and functionality.
2. Information sharing
The Company only shares PII with other companies or individuals in the following limited circumstances:
- As required for the provision of the Services, including, without limitation, sharing information with service providers (including for analysis and statistics), and with App Platforms.
- You may choose to share your photos and other PII with others on or through the Services. In addition, your scanned photos, other PII, and any other information that you voluntarily post on the Services, such as through your profile, may become visible by the public on the Services, subject to any applicable privacy settings that you set. If you do not want your scanned photos or other PII or information to be visible by others on the Services, please be sure to set your privacy setting to “Private”. Once you have shared your photos and other PII or information with others (via various channels available through the application), or set your privacy setting to “Public”, it may be re-shared by others. You are solely responsible for your decision to share your scanned photos and other PII and information with others and/or to make your scanned photos and other PII and information visible by others.
- We require opt-in consent for the sharing of any sensitive PII.
- We provide PII to our affiliates or other trusted businesses or persons for the purpose of processing PII on our behalf in Israel and/or abroad. We require that these parties agree to process such PII based on our instructions and in compliance with this notice and any other appropriate confidentiality and security measures.
- We have a good faith belief that access, use, preservation or disclosure of such PII is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable agreements and/or their terms, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
- If we obtain assurances from our agents that they will safeguard PII through measures consistent with this policy. Where we have knowledge that an agent is using or disclosing PII in a manner contrary to this policy, we take commercially reasonable steps to prevent or stop the unauthorized use or disclosure.
3. Information security
We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.
- We strive to maintain the reliability, accuracy, completeness and currency of PII that we collect and to protect the privacy and security of our users. We keep your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
- We limit access to PII about you to employees, contractors and agents who we believe reasonably need to come into contact with that PII. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
- We have physical, electronic, and procedural security measures and safeguards to reasonably protect PII. Our servers and our databases are protected by industry standard security technology, such as industry standard firewalls and password protection.
- Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, we try to prevent such unfortunate occurrences.
4. Data integrity, accessing and updating personal information
The Company processes PII only for the purposes for which it was collected and in accordance with this Policy or any applicable service agreements. We review our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve our Services. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.
- Upon receipt of your written request and enough information to permit us to identify your PII, we will disclose to you the PII we hold about you. Upon your request, we will also correct, amend or delete any PII that is inaccurate and notify any third party who received this PII from us of the necessary changes.
- We do not charge for complying with a correction request, however, for all other requests, we may charge a small fee to cover its costs. Requests to delete PII are subject to any applicable legal and ethical reporting or document retention obligations imposed on the Company.
- We ask individual users to identify themselves and the PII requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.
The Company regularly reviews its compliance with this policy. Please feel free to direct any questions or concerns regarding this policy or our treatment of PII by contacting us as provided above. When we receive formal written complaints it is the Company’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between the Company and an individual.
The Company may update this policy. We will notify you about significant changes in the way we treat PII by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Services. We encourage you to periodically review this policy for the latest information about our privacy practices.
7. Consent To Processing
By providing any PII to us pursuant to this policy, all users, including, without limitation, users in the United States, Israel and member states of the European Union, fully understand and unambiguously consent to this policy and to the collection and processing of such PII abroad. The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access the same and may be outside your country of residence. Some of the uses and disclosures mentioned in this policy may involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country. By submitting your PII through the Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this policy. If you do not consent to the terms of this policy, please do not use the Services.
If you have any questions about this policy, concerns about the way we process your PII, or if you wish to delete all information regarding your use of the Services, please contact us [email protected] .
9. Your California Privacy Rights and Do Not Track Notices
California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of PII to third parties for their direct marketing purposes. To make such a request, please send an email [email protected] . Please note that we are only required to respond to one request per customer each year. You are also advised that Company does not respond to “Do Not Track” signals.
Last Updated: May 20, 2015