Effective February 21, 2021
Last Amended February 21, 2021

This privacy policy sets out the data processing practices carried by Tangelo Games Israel Ltd. or any other companies under Tangelo Group ("Tangelo", "we" or "us"). The Tangelo website (the "Website"), services and applications (together, the "Service"), provided by us through the Tangelo Website, creates social online games, where people worldwide get the ability to engage, communicate and socialize with one another.

Tangelo is committed to maintaining the privacy of its users ("user", "you"). The following information describes how Tangelo collects and processes information about you when you use our Services.

Our Privacy Policy explains:

By using the Service or providing your Personal Information (as defined below), or access to such information, you consent to the terms of this Privacy Policy and to the practices described herein, and acknowledge that you are not required by law to provide your Personal Information to us, and do so willingly and in agreement with this Privacy Policy.


Using the Services on your Device

Users can access the Services on a "Device" which within this Privacy Policy – means a mobile phone, computer or a tablet. This Privacy Policy describes the practices in which Tangelo collects Personal Information (as defined below) in the course of the provision of the Services, and shall apply regardless of the manner in which access to the Services was provided.


Collecting Information

Please note that the scope of this Privacy Policy is limited only to information collected by Tangelo through your use of its Services. Some information may be automatically collected, and some is collected when you interact with our Services. The type of information that may be automatically collected is non-personal information, which includes your session durations, the content you accessed on the Service, the frequency and scope of your use of the Service and information about your Device and internet connection including the operating system you use and browser type.

Information from which you can be personally identified may also be collected, including but not limited to your first and last name, date of birth, credit card information, home or other physical address, email address, phone number or other contact information, profile picture, friends list, your mobile application store account and the location of the Device through which you used the Services (hereinafter: "Personal Information"). Personal Information will be collected from you including without limitation, via the following methods:


Registering to create an account

We will collect your Personal Information when you register to create an account to use the Services. Such information may include your contact information (including telephone number), shipping information, billing information, transaction history, website usage preferences, and feedback regarding the Services.


Information collected from third parties

We may also receive your Personal Information from online vendors and service providers, and from customer lists lawfully acquired from third-party vendors. When we will have access to information you provide to vendors, service providers and third-party e-commerce services, we will use such Personal Information only as set out in this Privacy Policy below.


Activity Log

When you interact with the Services, our servers keep an activity log. Such information includes certain administrative and traffic information such as: source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. This information is essential for the provision and quality of the Services.


The Personal Information you share

You may use the Service to publish and disclose Personal Information or content, for example by sharing it with others by link, post or attachment. Information that you publish and share may become available to the public at your own risk and sole discretion. Please note that even if you remove such content, copies may remain available in cached and archived pages. We take no responsibility with respect to content and information that you voluntarily publish, and such content may also become subject to the terms of use and privacy policy of the platform it is published through (i.e. Facebook or any other platforms).


Other information posts and permissions

When we propose you to invite friends to use the Service (whether in general or with respect to a specific survey), and you accept such proposal, we may (1) send your friend an email or message on your behalf using your name, or (2) post the invite to your friend's Facebook Timeline or any other platform option, by using the channels such platform provides. The invitation may also contain information about other users your friend might know. You may also be asked to allow Tangelo to post status messages and notes to Facebook or any other platform on your behalf. Please carefully review the content of such posts before giving your permission. Any information shared by you with your friends or marked by you as public, including Personal Information, may be published and disclosed by the Service. For example, questionnaire results made public or shared with your friends once may be shared with your friends again by Tangelo, by allowing a friend to compare between the questionnaire score of different users.


Use of Information

We use the Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.

a. Providing the Requested Services

We process the Personal Information where it is necessary for the adequate performance of the contract regarding the requested Services.

b. Improvement and Development of the Services

We process this information in light of our legitimate interest in improving the Services, to allow our users to have the best experience.

c. Maintain a Safe and Secure Environment

We may use your information to detect and prevent fraud, abuse and security incidents in the following ways;

We process this information in light of our legitimate interest in improving our Services and enabling our users to browse in a secure environment.

d. Personalize Content, Advertising and Marketing

We process this information in light of our legitimate interest to personalize your experience and customize our content.


Disclosure of Information and Transfer of Data

Except as otherwise provided in this Privacy Policy, we reasonably attempt to ensure that we never intentionally disclose any of your Personal Information, to any third party without having received your permission, except as provided for herein or otherwise as permitted or required under law.

In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties. We may as well share your Personal Information with our affiliates, subsidiaries or any third party service providers and individuals to facilitate our Services or any portion thereof, such as for providing technical support, processing your online transactions and maintaining your account. We may also share your information with analytics service providers for analytics services. Such analytics service providers set their own cookies or other identifiers on your Device, through which they can collect information about your usage of our Service. This helps us compile aggregated statistics about the effectiveness of our Services.

We may also share your data with our advertising partners after we have removed your name or any other personally identifying information from it, or have combined it with other people's data in a way that it is no longer associated with you.

The above mentioned third parties may be located in countries other than your own, and we may send them information we receive. When such third party service providers process your Personal Information on our behalf, we will assure that they comply with obligations similar to those which are set forth in this Privacy Policy. We will also assure that they will abide by our data privacy and security requirements, and will be allowed to use the Personal Information solely for the purposes we set. We will transfer your Personal Information while using appropriate and suitable safeguards, while using a variety of legal mechanisms, including contracts, to ensure your rights and protections travel with your data.

We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal obligation or inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the Services to perform an unlawful act or omission or take any act or omission that may damage Tangelo, its property and goodwill, or if there is an attempted breach of the security of the Service or a physical or property threat to you or others. The authority supervising such activities is the Israeli Privacy Protection Authority, and you have the right to file a complaint to it or any other relevant supervisory authority.

Your Rights

You have the right at any time to request to access or modify your information. To exercise these options, please contact us at [email protected] You may request access to all your voluntarily-provided Personal Information that we collected online and maintain in our database by sending a written request to [email protected]

If you want to delete or remove your Personal Information stored with us permanently, you may send an e-mail to [email protected] Please include "Delete my Information" in the subject line and your full name and e-mail address in the body of the e-mail. We will respond to your request in a timely manner, normally within thirty (30) days. Upon such request, we will make our best efforts to remove all your Personal Information from our database. However, please note that some information may not be deleted from all databases and backup records. If you have posted content on or through the Service, we may not be able to delete it and copies may remain viewable elsewhere to the extent it has been shared publicly, or was copied or stored by others. We may also retain certain Personal Information for customer service, legal and similar purposes. We reserve the right to keep all non-personal information and continue to use such information in accordance with this Privacy Policy after the termination of your account and deletion of all your Personal Information.

In some jurisdictions, in particular those located within the European Union (the "EU") or within the European Economic Area (the "EEA"), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:

  1. Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
  2. Object to the processing of your Personal Information for direct marketing purposes.
  3. Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
  4. Object to an automated decision-making (including profiling) in certain circumstances.
  5. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
  6. Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.

Generally, with regard to information collected on our Services, Tangelo is a "Data Controller". Therefore, if you wish to exercise the above mentioned rights, please contact us, and we will make our best efforts to fulfill your request.

If you wish to file a request regarding any of the above, you may contact us at: [email protected].


California Online Privacy Protection Act

CalOPPA requires commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers, to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. See more at: click here.

According to CalOPPA, Tangelo agrees to the following:

The California Consumer Privacy Act of 2018 ("CCPA") permits users who are California residents to request to exercise certain rights. If you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to your Personal Information. In particular, you can request to receive information on the following:

You can be rest assured that we do not sell your Personal Information. If you choose to exercise your rights, we will not charge you different prices or provide different quality of our Services, unless those differences are related to your provision of your Personal Information. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Moreover, you may designate an authorized agent to make a request on your behalf.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide, will only cover the 12 month period preceding your verifiable request's receipt. If, for some reason, we cannot reply within such time frame, our response will include an explanation for our inability to comply. If you wish to exercise your CCPA rights, please contact us at: [email protected]. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  1. Deny you goods or services.
  2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you with a different level or quality of goods or services.
  4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CAN SPAM Act

The CAN-SPAM Act is a Federal US law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out strict penalties for violations.

To be in accordance with CANSPAM, Tangelo agrees to the following:

If at any time you would like to unsubscribe from receiving future emails, you can email us at [email protected] and we will promptly remove you from ALL correspondence.


Advertising Practices

We may allow third-party advertising agencies and networks to serve advertisements, or may ourselves serve advertisements, through the Service. Such ads may be based on the information provided to us, other than Personal Information. We do not provide any Personal Information to such advertising agencies and networks. However, please note that if an advertiser asks us to show an advertisement to a certain type of users or audience, and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience they are trying to reach. You should consult the respective privacy policies of advertising agencies and networks. This Policy does not apply to, and we cannot control the activities of, third-party advertisers. Any solicitation of personal information through such advertisements is strictly between the advertiser and you. You may choose voluntarily whether or not to provide us with your Personal


Information.

Notices provided at the Service where we collect Personal Information should help you to make this choice. If you choose to avoid provision of your Personal Information as we request it, you may be unable to access and use certain options, offers and Services that involve our interaction with you.


Cookies

We may use "cookies" and/or other technologies or files (collectively, "cookies") to identify how users make use of the Services.

Cookies are data files, which often include a unique identifier, sent to your browser and placed on your Device in order to enable you to more easily communicate and interact with the Service and store certain information. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your Device until you delete them). Usually you can set your web browser to refuse all cookies or to indicate when a cookie is being received. However, some features of the Service may not function properly if the ability to accept cookies is disabled. Some of the content included in the Service, such as ads, may be provided by third parties, and this content may also contain and send cookies to your Device. To find out more about cookies, visit www.allaboutcookies.org.

We may also use "Beacons" or "Pixels" which are electronic files used to track your navigation through the Service, our Website or email messages sent to you, the completion of transactions, submittal of applications and browsing behavior. Furthermore, when you use the Service we may track and record actions occurring on the Service and collect certain technical data including your IP address, browser type, internet service provider, referring/exit pages, platform type, date/time stamp, click data and types of advertisements viewed.


Opt In or Opt Out

You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later.

You may opt out of having certain of your Personal Information collected by us or used by us to send promotional correspondences to you, by contacting us at- [email protected]. We will respond to your request in a timely manner, normally within thirty (30) days. Upon such request, we will make our best efforts to remove all your Personal Information from our database. However, please note that some information may not be deleted from all databases and backup records. If you have posted content on or through the Service, we may not be able to delete it and copies may remain viewable elsewhere to the extent it has been shared publicly, or was copied or stored by others. In the event you want to opt-out of Tangelo marketing emails, you may do so at any time by clicking on the unsubscribe links located within each Tangelo email. Please note that opting out may affect your ability to receive information from Tangelo access to all of the Services.


Links to Other Websites

The Services may provide links to other websites. Please be aware that these other websites are not covered by our Privacy Policy. This Privacy Policy does not cover the information practices exercised by other providers of products or services, advertisers or other websites, companies or individuals, which are not owned or controlled by Tangelo. We suggest that when linking to another website, you always read that website’s privacy policy before volunteering any personally identifiable information.


Data Security

We deploy industry standard measures to ensure the security, confidentiality, integrity and availability of the Personal Information we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Information on a ‘need to know’ basis for the provision of Services to you. No such measures are perfect or impenetrable. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our Services and transmission is at the users own risk.


Data Retention

Generally, Tangelo does not retain information longer than necessary to provide its Services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your Personal Information, we will erase your Personal Information from our systems, unless the Personal Information is required for Tangelo to establish, exercise or defend against legal claims or it is necessary for the performance of the requested Services.


Children's Privacy

The Service is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age.

IF YOU ARE UNDER THE AGE OF 16 YOU MAY NOT USE THE SERVICE, UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY


Questions Regarding Our Privacy Policy

If you have any questions regarding this Privacy Policy or the practices described above, you are always welcome to contact us at [email protected].


Revisions and Modifications to our Privacy Policy

We reserve the right to revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly. Please review this Privacy Policy often so that you will remain updated regarding our current policies.


Governing Law and Jurisdiction

This Privacy Policy will be governed and interpreted pursuant to the laws of the State of Israel without giving effect to its choice of law rules. You expressly agree that the exclusive jurisdiction for any claim or action arising out of or relating to this Privacy Policy shall be to the competent courts in Tel Aviv, Israel, to the exclusion of any other jurisdiction.