Privacy Policy

Last Revised: 15 July 2018
VelisMedia Ltd. (“VelisMedia”, “we”, “our”, or “Company”) welcomes you, a visitor of our website at
www.velismedia.com (“Website” or “Site”) and third party advertisers (“Advertisers”) and third-party publishers
(“Publishers”) using our service as detailed below.
VelisMedia is an online platform enabling our Advertisers to display advertisements and marketing materials to end
users who use or otherwise interact with certain mobile webpages and desktop websites (“Digital Assets”) owned
by our Publishers (collectively, the “Services”).
For the purposes of this privacy policy (“Privacy Policy”) a “User” shall refer to a visitor of the site, an Advertiser or
Publishers as well as their applicable end users.
Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms and Conditions
available at: http://www.velismedia.com/terms_and_conditions.html which this Privacy Policy is incorporated
thereto by reference (collectively, the “Terms”).
We have included below information about which data is collected, how we process and use your data, but before
we would like to explain the basis on which we do so:
1) Where you sign up for any of our Services, we process your personal data in order to perform our contract
with you;
2) If we have a legitimate interest in processing data, such as for direct marketing, online advertising or online
identifiers when you access our Site or use our Services; or
3) We will also process your personal data where you have provided us with consent to do so.
INFORMATION WE MAY COLLECT
We may collect two types of data and information from our Users. The first type of information is non-identifiable
and anonymous information (“Non-Personal Information”). We are not aware of the identity of the User from which
we have collected the Non-Personal Information. Non-Personal Information is any unconcealed information which
is available to us while Users are using the Services. Non-Personal Information which is being gathered consists of
technical information and behavioral information, and may contain, among other things, the activity of the User on
the Services, type of operating system and type of browser, type of device, User’s connection to the Site, or
approximate geo-location.
The second type of information is individually identifiable information, namely information that identifies an
individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information
includes either: (i) contact information such as your name, email address, etc., which you have submitted voluntarily;
or (ii) your Internet Protocol (“IP”) addresses (the addresses of computers on the Internet), advertising ID, IDFA
(collectively, “Identifiers”). Note that, while Identifiers are considered Personal Information in many jurisdictions
(such as the EEA), there are some jurisdictions in which such data is not considered as Personal Information.
Therefore, we treat such information as Personal Information, in accordance with applicable laws, however we do
not attempt to analyze or determine your identity based on such information or otherwise combine it with any
Personal Information such as your name or email address. The IP may be collected by our third party analytic
partners that offer ways to opt-out, all as detailed below.
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.
You are not required by law to provide us with any information. You can always avoid from providing us certain
Personal Information; however, you acknowledge that it may prevent you from engaging in certain Services.
Information we collect from visitors of our Website and Users of the VelisMedia Service
Type of Information How Do We Use It?
In the event you contact us for support or other inquiries,
either through the online form available on the Website, by
sending us an email or by other means of communications
we make available, you will be requested to provide us your
name and email address.
We will use this information solely for the purpose of
responding to your inquiries and provide you with the
support or information you have requested.
In the event you are interested in joining our team, and wish
to submit your CV, you will be required to provide us your
name, email address, and CV.
Your provision of personal information in connection
with recruiting is voluntary, and you determine the
extent of information you provide us. We do not request
or require sensitive personal information concerning
religion, health, sexual orientation, or political affiliation
in connection with recruiting. We will use the
information you have provided solely to communicate
with you, to manage our recruiting and hiring processes,
and for compliance with corporate governance and legal
and regulatory requirements. If you are hired, the
information may be used in connection with
employment and corporate management.
Identifiers We either directly or indirectly may collect our visitors’
of the Site IP or Identifiers when using the Services. We
use this for our legitimate interests of operating,
providing, maintaining, protecting, managing,
customizing and improving our Site and Services and the
way in which we offer them; (ii) enhancing your
experience with the Services; (iii) our legitimate interests
of auditing and tracking usage statistics and traffic flow;
and (iv) our legitimate interest of serving personalized
advertisements on Digital Assets.
We also collect certain technical Non-Personal Information
(as detailed above) which relates to your use of the Services
or the Website.
We use this technical data in order to operate and
manage our Website.
Information We Collect from Advertisers or Publishers
Type of Information How Do We Use It?
In order to use our Services as an Advertiser or Publisher you
will be required to enter into a physical agreement with
VelisMedia.
We will use this information for the purpose of
performing our contract with you in order to provide you
with the Services you have requested.
We also collect certain technical Non-Personal Information
(as detailed above) as a visitor to the site and as detailed
above.
See the table above.
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with the Services, we may collect information as follows:
(i) Automatically – we may use Cookies (as elaborated in the section below) to gather some information
automatically.
(ii) Provided by you voluntarily – we will collect information if and when you choose to provide us with
the information, such as through a physical agreement, contact us communications, etc. all as detailed
in this Privacy Policy.
SHARING INFORMATION WITH THIRD PARTIES
VelisMedia will not share any Personal Information it collects with any third party. Notwithstanding, VelisMedia may
disclose Personal Information in the following cases: (i) Compelled Disclosures. To satisfy any applicable law,
regulation, legal process, subpoena or governmental request; (ii) Enforcement of our Rights. To enforce this Privacy
Policy and/or the Terms of Use, including investigation of potential violations thereof; (iii) Fraud Detection. To
detect, prevent, or otherwise address fraud, security or technical issues; (iv) Business Transfers. When VelisMedia
is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all
of its assets; (v) Service Providers. To collect, hold and/or manage your Personal Information through VelisMedia’s
authorized third party service providers, as reasonable for business purposes; (vi) Explicit Consent. Pursuant to your
explicit approval prior to the disclosure; or (v) Identifiers. We may share identifiers collected by us (as detailed
above), for the purpose of operating our business and providing the Services, as well as to calculate payments in
connection with the Services.
For avoidance of doubt, VelisMedia may transfer and disclose or otherwise use Non-Personal Information or
information which is linked to anonymous random identifiers or information that is aggregated in a non-identifiable
way, at its own discretion.
DATA RETENTION
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in
accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole
discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer
necessary for such purposes.
USER RIGHTS
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 Information. Subject to the limitations in applicable law, individuals may also be entitled to obtain
from us the Personal Information they have provided to us in a structured, commonly-used, and machine-readable
format, and may have the right to transmit such Personal Information to another party.
The principal rights under applicable data protection law in relation to Personal Information are as follows: 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; 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 Information, depending on your relationship with us. For more information, please review our user right
policy and online forms available at: www.velismedia.com/PDF/UserRights.
If you wish to exercise any or all of the above rights, please either use the dashboard of your account or please
contact our Data Protection Officer at: dpo@velismedia.com and let us know that you wish to exercise your right of
access and specify what Personal Information you would like to receive. Further, we enable an electronic form to
contact us directly regarding an applicable user right request available at: www.velismedia.com/PDF/UserRights.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain
the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. 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.
THIRD PARTY SOFTWARE/SERVICE
While using the VelisMedia Services we may be using third party software and/or service for various needs, inter
alia, in order to collect and/or process the information detailed herein (“Third Party Service Provider”).
Note that these are independent software and/or service providers and VelisMedia does not take any liability about
the information collection policies of these providers relating thereto. Currently, our Third Party Service Providers
are the following (we will update this section from time to time if we add or remove Third Party Service Providers):
• Google Analytics this cookie is placed in order to track and analyze the use of our Services, for internal
purposes. To learn more about how Google uses data from our use of Google Analytics Cookies, we
recommend you review Google’s policies located at: www.google.com/policies/privacy/partners. We also
encourage you to review the Google Analytics’ currently available opt-outs for the web tool available
at: https://tools.google.com/dlpage/gaoptout.
• Voluum which privacy policy can be found at: https://voluum.com/privacy-policy/
USE OF COOKIES
When you access or use our Site, the VelisMedia may use industry-wide technologies such as “cookies” (or similar
technologies), which store certain information on your computer (“Local Storage”) and which will allow us to enable
automatic activation of certain features, and make your service experience much more convenient and effortless.
The cookies used by the Site are created per session, which does not include any information about you, other than
your session key and are removed as your session ends. 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. However, if you block or erase cookies your online experience may be limited.
In this regard, following are some links which you may find useful:
Browser Opt-out:
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en;
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
• Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-deletemanage-cookies;
• Safari: https://support.apple.com/kb/PH21411;
• Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;
• Opera: http://www.opera.com/help/tutorials/security/cookies/ ;
Mobile Opt-out:
• Learn how to opt-out from Android-https://support.google.com/ads/answer/2662922
• Learn how to opt-out from iOS– https://support.apple.com/en-il/HT205223.
• You may control how your browser responds to cookies by adjusting the privacy and security settings of
your web browser.
Self-Regulation Opt-out:
You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator
services such as (1) the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or (2)
the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page or (3) If you wish to opt out of interest-based
advertising, you may click here. Please note you will continue to receive generic non targeted ads.
In the event, that you have any additional complaints about your privacy rights, please initially contact the Data
Protection Officer at: dpo@velismedia.com and we will be happy to assist you. Note that once you opt out, part of
the Services provided by us might no longer be available and some features may not work if you revoke the data
transfer. Please note that you have the right at any time to contact your local data protection authority.
SECURITY
We take great care in implementing and maintaining the security of Company’s Website, VelisMedia Services and
your information. We employ industry standard procedures and policies to ensure the safety of our users’
information and prevent unauthorized use of any such. We have implemented technical, physical and administrative
security measures to protect the Personal Information, including without limitation by using industry standard
encryption (SSL). In addition, we limit access to your information on our servers. The data collected by us is stored
in the AWS data servers, for more information regarding the data security provided by AWS, please see:
https://aws.amazon.com/security/.
For additional information regarding our security measures please see www.velismedia.com/security. Although we
take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain
unauthorized access or abuse Company’s Services, and we make no warranty, express, implied or otherwise, that
we will prevent such access.
PROTECTING CHILDREN
The VelisMedia Services are not directed to children and we do not knowingly collect information from children. If
you have any information regarding a use of a minor under the age of eighteen (18) please let us know at:
dpo@velismedia.com. You must be at least eighteen (18) years of age to use the VelisMedia Services. By agreeing
to these Terms, you represent and warrant to us: (i) that you are at least eighteen (18) years of age; (ii) that you
have not previously been suspended or removed from the VelisMedia Services; and (iii) that your registration and
your use of the VelisMedia Services is in compliance with any and all applicable laws and regulations.
CHANGES TO THE PRIVACY POLICY
The terms of this Privacy Policy will govern the use of the VelisMedia Services and any information collected therein.
VelisMedia reserves the right to change this policy at any time, so please re-visit this page frequently. In the event
of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the Site. Such
substantial changes will take effect seven (7) days after such notice was provided on the VelisMedia Services or sent
by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and
your continued use of the VelisMedia Services after the Last Updated date will constitute acceptance of, and
agreement to be bound by, those changes.
DATA TRANSFER
We may store or process your Personal Information in the United States or in other countries. If you visit our
Websites or use our Services from locations outside of the United States, please note that any information you
provide to us through your use of our Websites or Service may be transferred to and processed in countries other
than the country from which you accessed our Websites or Service, including the United States where our central
database is operated. If you are a resident of the European Economic Area (“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 consent
to this Privacy Policy includes your express consent for such transfer of your data.
DO NOT TRACK DISCLOSURE
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please
see: http://www.allaboutdnt.com/.
ADDITIONAL INFORMATION AND CONTACT US
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at:
dpo@velismedia.com or mail us at: Velis Media Ltd. Zeev Jabotinsky 7, Ramat Gan, Israel, and we will make an effort
to reply within a reasonable timeframe.
By contacting VelisMedia you warrant and agree that you are free to do so, and that you do not provide VelisMedia
with information, which violate any third party intellectual rights (“Information”). Without degrading from the
aforesaid, all rights, including intellectual property, arising from the communication will be owned by VelisMedia
and will be considered as VelisMedia’s confidential material. It is clarified that any use of the Information, will be
done in VelisMedia’s sole discretion, and VelisMedia is not obligated to use all or part of this Information.
DATA PROTECTION OFFICER
If you have any requests regarding the data collected under this Policy, including without limitation, requests to
remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at:
dpo@velismedia.com. Please include your name, address and email address in any correspondence so that we can
respond to your inquiry or request.