We may use Information gathered through our platforms and Services in different ways, depending on whether you are (i) seeking to publish, advertise, or any provider who has a contractual relationship with ForeMedia (“Customer”); (ii) a user of our Customers’ platforms and digital properties who interacts with our Services (“User”); or (iii) a visitor to the ForeMedia direct platforms (“Site Visitor”), which may include Customers as well as prospective customers.
Personal Data We Collect
We may collect the following information about You(“You” as in – “Customer”, “User”, or “Site Visitor”) – when using either one of ours’, affiliates’ and/or customers’ services:
- All Data and information that solely and directly identifies you. This may include your name, address, email address, username, and password.
- Data and Information that indirectly identifies you. We automatically receive and record information from your web browser or device when you use our platforms and services, for example, your internet protocol (IP) address, mobile device ID, time zone setting, location data, language preference, operating system, platform, and links you have clicked on or shared with others, including through email and social media. We may also create a user ID that may correspondingly indirectly identify you. We may use this information to collect information about your activities on our website and/or on third-party platforms, such as Facebook. We may associate information that indirectly identifies you with your user account (if you have one) and other information we have collected about you.
- Location data. We may gather geographical-data, which shows us your location when we acquire other information about you. We may also collect the language preference or country you choose. We may link geo-data to other information we have collected about you.
- Profile data. This may include your username and password and other information you give us (for registered users), the information you give us regarding purchases or orders made by you, your interests, preferences, feedback and survey responses. Profile information you enter in your account profile (for registered users), including your username, may be shown to other users to facilitate user interaction on our website or platforms. We do not disclose email addresses to other users.
- Marketing and communications data. This may include information about your subscriptions to newsletters and your marketing preferences.
- Transaction and financial data. We may gather or save transactional and financial information relating to you when you buy something through our website or platforms (for example payment details) or in any case where you have bought a product or service from a third party after clicking on an affiliate link in our content.
- Special data. When we conduct research or carry out surveys we may gather private personal information about you, for example, information about your racial or ethnic origin and/or any sensitive data. We will not use or share this information without your explicit consent.
We accumulate the personal information we gather, such as the number and frequency of your visits to our website, to produce statistical information. We may share this data with third parties.
We share anonymized, accumulated information with marketing partners and service providers we work with so that we, and they, can discern how people use our services; this helps us grow our business and develop fitting products and services. These third parties may share with us information about you that they have independently developed or acquired.
We combine information about you with information about other users to create audience division of acquired data, for example, statistics, demographics and usage data. If we combine or link accumulated data with personal data we consider the combined data as personal data and deal with it in accordance with this privacy notice.
Customers – Usage, Disclosure, and Choice
We use and disclose Customer Information that we collected about the Customer for the following purposes:
- Providing our Service. To provide our platforms and Services and for other customer service purposes in relation to the Customers’ accounts.
- Marketing and advertising. To provide Customers with newsletters, offers, and promotions, including via email; to contact Customers about products or services we think may interest them; and for other marketing, advertising, and/or promotional purposes, and general updates about ForeMedia. These communications will be sent in accordance with our Customers’ communications preferences.
- ForeMedia service providers. We may disclose Customer Information to service providers, agents, contractors, and/or others who perform functions (e.g., fraud detection, data hosting, maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing) for us.
- Customers. We may disclose Customer Information to other Customers who have relevance to the Services we provide. For example, we may provide publishers with information about what advertisers may appear on their network or advertisers with information about which publisher websites they have appeared on.
Customers may access, revise, or update the Information they have given to us by either updating the Information in their account, by emailing their devoted account manager, or by emailing us at [email protected]
We may send recurrent promotional or informational emails to Customers incongruity with their communications preferences. At any time, Customers may opt-out of said communications by following the opt-out instructions enclosed in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt-out of accepting emails about suggestions or other information we believe may interest you, we may still send you emails about your account or any Services that you have requested or accepted from us.
Users – Usage, Disclosure, Choice, and Special Categories
We use and disclose User Information that we collected about the Users for the following purposes:
- Providing our Service. To provide our Services to Users and our Customers.
- Tailoring content. To tailor the content and information that we may send or display to Users; to target content to Users through our Services and other platforms; and to otherwise specially create, personalized experience for you while using our Services. For more information about how we tailor our content see information below about our Interest Based Advertising.
- Tailoring content across multiple devices. To improve a Users’ experience across multiple platforms, portals and/or devices by providing better-targeted ad campaigns to that unique User. For example, when we recognize a User on a web browser, we may want to provide that User similar or personalized content on mobile apps, as well. To do this, we identify unique Users across multiple platforms, or we may sync identifying cookies with our service providers or Customers that also use this method to help our Customers enhance their own data and insights, to help them obtain or provide customer performance results to other marketers.
- Offering our Customers data segments that help target content and advertisements for services, topics, and products that may interest you. A data segment is a grouping of users who share one or more attributes (e.g., coffee enthusiasts). We offer a number of data segments, both in the custody of the company and from our data partners to our Customers so that they may better target Users who are more likely to be interested in their content and offers. ForeMedia does not knowingly create segments that are based upon what we consider to be sensitive information (for example, personal data revealing your racial or ethnic origin). However, in connection with our Services, our Customers may use standard health-related segments about non-sensitive conditions such as an inferred interest in health and wellness or no-prescription medications.
- ForeMedia service providers. We may allow access of User Information to vendors, service providers, agents, contractors, or others who operate (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, or fraud detection) on our behalf.
- Unaffiliated third parties. We may disclose User Information to other unaffiliated third parties, specifically with (i) our data providers, so that we can associate you with relevant content by allowing our advertisers to target specific viewer sections, and (ii) our programmatic demand and supply partners so that we can serve you with tailored advertisements
- Customers. We may disclose User Information to Customers where relevant to the Service we provide those Customers. For example, we may provide publishers with information about the viewing and click-through patterns of the content they publish and may provide advertisers with information about conversion rates for analytics purposes.
You have the right to request that ForeMedia provides you with access to the personal data we have about you, correct personal data related to you, delete your data, and cease or restrict the processing of your personal data. You can do it through a request sent to our support team [email protected]
Using our Services, whether on-site and off-site(Services on Customer websites), we may provide advertisements to you based on your latest browsing patterns across different Customer Websites, Browsers, and/or Devices. For example, if on a first online visit, you browse on website A, and then another visit to website B, you may see content especially tailored for you based on your browsing history on website A. For example, if a user visits a travel services site, she might see travel-related ads on another site she visits.
If you have questions about our collection and use of data for interest-based advertising purposes, please contact us at [email protected]
We save User Information, which is directly collected for purposes of serving ads, for as long as eighteen months(18 months) from the User’s last use with our Services, after which time we de-identify the data by removing unique identifiers or aggregating the data.
We retain de-identified or accumulated data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as commercially necessary.
We do not knowingly collect any data or target an advertisement on a website directed to children under the age of thirteen (13). If you are the parent or guardian of a child under the age of thirteen (13) and have a concern regarding the Information we collect, please contact us at [email protected].
Protecting Your Data
We take steps to keep your information safe by incorporating appropriate security measures to prevent personal data from being lost, used, accessed in any illegal way, altered or exposed.
We limit access to your personal data to any of the personnel(including third-parties, contractors, etc.) who need to access it. They are subject to a clause of confidentiality and we require them to process your personal data only with our instructions.
We do not guarantee and/or warrant that security measures will prevent data breaches. We have protocols to deal with suspected breaches. We will notify you and the relevant regulator of any data breach as legally required.
Legal Basis – Processing Personal Information
If you are a Customer, Site Visitor, or User from the European Economic Area, our legal basis for gathering and using the Personal Information described above (referred to in this Section as “EEA Data”) will depend on the Personal Information concerned and the context in which we acquire it.
However, we will normally collect Personal Information from you only (i) where we have your approval to do so, (ii) where we need the Personal Information to create and execute a contract with you, or (iii) where the using and analyzing is in our legitimate interests and not blocked by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.
If we ask you to disclose Personal Information to comply with a legal obligation or to undergo a contract with you, we will make this clear at the relevant time and suggest whether the provision of your Personal Information is obligatory or not (as well as of the possible consequences if you do not provide your Personal Information).
Similarly, if we collect and use your Personal Information, relying on our coinciding interests (or those of any third party), we will make it clear to you at the relevant time what those coinciding interests are.
If you have questions or need further information regarding the legal basis on which we gather and use your Personal Information, including if you would like to better understand our legitimate shared interests to process your data protection rights and freedoms, please contact us using the contact details provided under the “Contact Us” heading below.
Your Rights to Your Information
You have the right to ask that ForeMedia (i) grant you access to the Personal Information we acquired about you, (ii) correct/fix/rewrite your Personal Information, (iii) delete your Personal Information, and (iv) stop or limit the processing of your Personal Information. If you are a User and would like to better understand what Personal and/or Behavioral Information ForeMedia holds about you in our database, specifically, and how you can exercise any of your rights with respect to your Personal Information, please contact us at [email protected] Our Customers may also request access to their data by emailing us at [email protected] so that ForeMedia may, if applicable, either respond with the relevant information or, direct this request to, and cooperate with, your employer to reply.
You have the right to seek out and complain to a data security authority about our collection and use of your Personal Information. To know more, please reach out to your local data protection authority, using the contact methods accessible here. However, if you require any further assistance in relation to our collection and use of your Personal Information, please first contact us at [email protected]
EEA Data Transfers
ForeMedia shares data outside the EEA. ForeMedia relies on sufficiency determinations because data is controlled and stored by ForeMedia’s Israeli entity. Furthermore, ForeMedia also uses an Inter-Group Data Transfer Agreement across its international entities, which is based on the standard model clauses.
Intertwined with ForeMedia’s global operations, our data is accessible to the EEA, the United States, Israel, and Hong Kong. To ensure that EEA Data is properly protected when transferred outside the EEA, the Data Protection Directive 95/46/EC and, as of May 25, 2018, the General Data Protection Regulation mandate that these transfers take place using certain legal mechanisms.
When handing over EEA data to Israel, ForeMedia relies on the European Commission’s determination that Israel offers sufficient data protection for transfers from the EEA. When transferring EEA data elsewhere, ForeMedia relies on the European Commission’s accepted Standard Contractual Clauses, which are contractual privacy and security commitments between companies that alternate personal data (for example, from ForeMedia to ForeShop Group, LTD.). ForeMedia and its Affiliates have taken Standard Contractual Clauses, accordingly, to ensure the legality, privacy, and security of the data flows needed to provide, maintain, and advance our services.
Note: ForeMedia stores Customer, User, and Visitor Information in our data centers, currently, located in the United States and Israel.
International Data Transfers
We may move your Information outside the country in which it is gathered, including to a country that may not offer the same protection of Personal Information as of the country in which you are currently residing. However, ForeMedia has arranged all contractual safeguards to make sure your Information is being processed in a way that provides an adequate level of protection when it is shared – between and/or among ForeMedia Affiliates and/or parent companies.
Browsers and devices have tools that allow you to disable cookies on sites and apps. If you disable cookies you may not be able to use all of the features of our services. We suggest that you keep our essential cookies (as described below) active for a better experience and to help us improve constantly and develop our products and services.
Session cookies remember your actions during your session on our sites and apps. They are deleted when you finish using our website or close the web browser.
Analytics cookies are used by us and by third parties who analyze data for us for processing purposes (for example Google Analytics) so that we can improve the performance and the visuals of our sites and apps and for continuous monitoring and researching of the data.
Consent cookies may be used by consent management tools we engage in our websites to allow us to record and monitor your preferences about third party cookies described in the above sections and to store and share your preferences with us.
We may compile the following personal data through essential cookies: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken on our sites and apps; time and date of those actions; country and language selected.
Our ad partners and our affiliate links partners may collect personal data from you for their own purposes.
- Ad partners include ad networks such as third-party ad servers, ad agencies, ad technology vendors and research firms.
- Affiliate links partners pay us when you buy things from them or another third party after clicking on an affiliate link in our content.
If you have questions about the privacy aspects of our platforms or Services, please contact us at:
ForeShop Group LTD – ForeMedia Division
Raoul Wallenberg 4 Tel Aviv,
Entrance Floor, Israel 6971904
Tel: +972 53 724 1891
Email: [email protected]