FORTVISION PRIVACY POLICY
Effective date: May 25, 2018
General Information
FORTVISION is dedicated to providing Internet users the highest level of transparency and control over the use of their data in online advertising and their engagement with FORTVISION content. FORTVISION adheres to the Interactive Advertising Bureau’s (IAB) Self-Regulatory Principles for Online Behavioral Advertising.
FORTVISION provides a platform where content creators such as publishers, eCommerce, games (“Customers”) can create, embed and share interactive content units, including but not limited to: online quizzes, questionnaires, feedback applications or other features ("Service"), that can be distributed and offered on their website, application, mobile app or service (“Site”) and the users of the Customer Site can interact with (Users”). In this policy "Customer" refers to any third party that downloads, implements or makes use of FORTVISION Service.

FORTVISION together with its Affiliates (FORTVISION, “we”, “us”, or “our”), recognizes the importance of privacy. In this privacy policy ("Privacy Policy") we describe how we collect, process, use, and disclose information that we obtain through our service using the website, www.FORTVSION.com, or any other FORTVISION web pages (collectively, the “Sites”) or other applications or third-party sites & apps that we may use our product (collectively, the “Services”).

When you visit the Sites, or use or interact with any of our Services, we will collect information from or about you or your device, including personal information, (“Information”), and this Information will be handled as described in this Privacy Policy. Such information includes IP-address, Session ID, browser type, mobile or desktop ID, referrer, user language and feedback or answers provided by the User to any interactive content unit made available with the Service. Such information may qualify as Personal Information in some Users’ jurisdictions, however, we do not make any use of such data to directly identify individuals or to associate it with individuals.

We may use Information collected through the Sites and Services in various ways, depending on whether you are (i) a publisher, advertiser, or other content provider with whom FORTVISION has a contractual relationship, ("Customer"); (ii) a visitor to our Customers' websites and digital properties who interacts with our Services ("User"); or (iii) a visitor to the FORTVISION Site ("Site Visitor"), which may include Customers as well as prospective customers. Therefore, we have distinguished the relevant information that relates to each of these target categories into three different sections below. Information that is relevant to all three of these categories is set forth below.
Customers
Information We Collect from Customers (“Customer Information”)
We collect Customer Information directly from our Customers: contact details when a Customer register to our Service which include username, password, name, email address, telephone number, payment card information, billing information and any other Information the Customer may choose to provide to us when creating an account. We may also work with third party vendors to process payments to or from our Customers on our behalf.

We will normally collect personal Information from you only (i) where we have your consent to do so, (ii) where we need the personal Information to perform a contract with you, or (iii) where the processing is in our legitimate interests and not overridden 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 provide personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal Information is mandatory 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 in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

When a Customer sends us an email asking a question, or signs up to receive our email newsletters, we will collect the Information that the Customer submits to us. We will also collect other Information that Customers choose to provide to us, such as the contents of a message that a Customer submits through our Sites or via email. We may also collect Information from prospective Customers through publicly-available sources.


How We Use Customer Information
To provide our Sites and Services and for other customer service purposes in relation to Customer accounts. To communicate, via email or otherwise, with Customers about the Customers’ accounts; to respond to Customer inquiries, requests, or complaints; and to provide Customers with news, best practices, or other helpful or interesting information, in accordance with their communications preferences. When we communicate in this way, our emails may deploy a cookie that tracks when the emails are opened and measures campaign performance. For more information about cookies, please see our Cookie Policy and to provide Customers with newsletters, special offers, and promotions, including via email; to contact Customers about products or services; and for other marketing, advertising, promotional purposes, and general updates. These communications will be sent in accordance with our Customers' communications preferences.


How We Disclose Customer Information
We may disclose Customer Information to any of FORTVISION's current or future affiliates. We may disclose Customer Information to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, fraud detection) on our behalf. We may disclose Customer Information to other Customers where relevant to the Service 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.


Customer Choices
You have the right to request (i) provide you with access to the personal Information we hold about you, (ii) correct your personal Information, (iii) delete your personal Information, and (iv) cease or restrict processing of your personal Information. If you would like to understand what personal Information and behavioural information FORTVISION holds about you, specifically, and how you can exercise any of your rights with respect to your personal Information, please contact your dedicated customer success or by emailing us at support@FORTVISION.com.

We may send periodic promotional or informational emails to Customers in accordance with their communications preferences. At any time, Customers may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to fourteen (14) business days for us to process opt-out requests. If you opt out of receiving emails we may still send you emails about your account or any Services that you have requested or received from us.

You have the right to complain to a data protection authority about our collection and use of your personal Information. If you have any questions about our collection and use of your personal Information, please first contact us at support@FORTVISION.com. If you are unable to obtain the information or resolution that you seek, you may also contact our Data Protection Officer at DPO@FORTVISION.com.


Users
Information We Collect from Users (“User Information”)
We automatically collect User Information when Users interact with our Services on our Customers' websites and mobile applications. We collect this User Information through cookies and other technologies. FORTVISION collects only pseudonymized data, which means we do not know who you are because we do not know or process your name, email address, or other identifiable data. User Information that we collect includes, but is not limited to, Information about a User’s device and operating system, IP address, the web pages accessed by Users within our Customers’ websites, the link that led a User to a Customer's website, the dates and times a User accesses a Customers' website, event information (e.g., system crashes, battery status), and general location information (e.g., city and state). We ask our Customers to obtain consent on our behalf, where required by applicable data protection laws, for us to collect this User Information.

Through our Services, including our Services on Customer websites, we may provide content and advertisements to you based on your recent browsing behavior across different Customer websites, browsers, or devices. In order to target personalize advertisements we may use cookies, JavaScript, web beacons (including clear GIFs), HTML5 local storage, and other technologies. For more information about how we use these technologies, please refer to our Cookie Policy. We may also use third parties such as ad networks, which are third parties that display advertisements based on your visits to websites that you have visited in the past. These advertisers will deliver you personalized advertisements for products and services. Third-party ad networks, advertisers, and/or traffic measurement services may also use cookies, JavaScript, web beacons (including clear GIFs) and other technologies to measure the effectiveness of their ads and to personalize advertising and other content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.


How We Use User Information
To provide our Services to Users and our Customers. To personalize the content and information that we may send or display to Users; to retarget content to Users through our Services and elsewhere and to improve the User’s experience across multiple browsers and devices by providing better targeted ad campaigns to that User. To do this, we identify unique Users across devices, or we may sync cookies and identifiers with our service providers or Customers that do this, to help our Customers enhance their own data and data segments, or to help them obtain or provide customer insights to other marketers.


How We Disclose User Information
We may disclose User Information to any current or future Affiliates to process for the purposes described in this Privacy Policy. We may disclose User Information to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, or fraud detection) on our behalf. Disclose to other unaffiliated third parties, specifically with (i) our data partners, so that we can connect each user with personalize content by allowing our advertisers to target specific audience segments, and (ii) our programmatic demand partners, so that we can serve you with personalize advertisements. In addition, We may disclose User Information to Customers where relevant to the Service we provide those Customers.


Users Choices and Accessing Your Information
FORTVISION supports initiatives to offer our Users greater transparency and control over the uses of their Information. Therefore, we offer the following options for controlling the interest-based content and ads you receive. Opting out will opt out will prevent us from using your Information. Because our tracking mechanisms operate at the device and browser level, to fully opt-out across devices, you will need to do so on each device and browser individually. If your browsers are configured to reject cookies, your opt-out may not be effective, since we identify your choice to opt-out based on an opt-out cookie we deliver to you. In this case, you will need to confirm that your browser is configured properly in order for the opt-out to be effective. If you are using a Safari browser on iOS11 or macOS High Sierra, you must first adjust your Privacy and Security Settings to turn off both “Prevent Cross-Site Tracking” and “Block All Cookies”, and then return to this privacy policy or your preferred opt out platform to reset your opt out preferences.

You have the right to request access to the personal data we hold about you, correct your personal data, delete your personal data, and cease or restrict processing of your personal data. Please click here to make such a request.


Data Retention
We retain User Information, which is directly collected for purposes of personalize content and serving ads, for at most eighteen (18) months from the User’s last interaction with our Services, after which time we de-identify the data by removing unique identifiers or aggregating the data. We retain deidentified or aggregated data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as commercially necessary. We keep opt-out information for longer than this period so that we can continue to honor opt-out requests.


Children
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 immediately to support@FORTVISION.com



General provisions applicable
How We Use Your Information
To better understand how Customers and Users access and use our Site and Services, both on an aggregated and individualized basis; to respond to Customers’, and Users’ requests and preferences; and for other research, analytical, and statistical purposes.

Statistical Information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be improved and tailored to customer desires. Statistical Information is anonymous and does not, in and of itself, identify any specific end user or customer of FORTVISION. FORTVISION may share such Statistical Information with its partners or any third party, without restriction, on commercial terms that Apester can determine in its sole discretion. To comply with applicable legal obligations, including requests from law enforcement or other governmental entities. To protect our rights and interests and the rights and interests of our Customers and Users and the general public, as well as to enforce this Privacy Policy and our Terms of Use.


Disclosing Your Information
When we share your Information with third parties as specified above, we require such recipients to agree to only use the Information we share with them in accordance with this Privacy Policy and our contractual specifications and for no other purpose than those determined by us in line with this Privacy Policy. We reserve the right to disclose and/or transfer Information to another entity if we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of any other similar business transfer. We may disclose Information in order to comply with the law, regulation, a judicial proceeding, subpoena, court order, or other legal process. We may disclose Information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which we are involved. We may disclose to our Customers and other third parties aggregated or de-identified information about users for marketing, advertising, research, or other purposes.


Third-Party Links
Our Sites and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information security nor privacy practices of such third-party websites. These features may collect certain information, such as your IP address or the page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or directly on our Sites. Your interactions with these features are governed by the privacy policy of the company providing such features. As another example, our Services link to Customer websites, which are also not governed by this Privacy Policy but by the applicable Customers’ privacy policy.


Security
We value the security of your Information, including but not limited to the Information collected via the Sites or Services. We have taken appropriate technical and organisational measures to protect the Information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. Please be aware, however, that no data security measures can guarantee 100% security.

FORTVISION is using Microsoft Azure and AWS Amazon cloud services. Most of the servers and databases are located in Europe. As part of our global operations, our data flows between Europe and Israel. To ensure that EEA Data is adequately 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 such transfers take place using certain legal mechanisms. When transferring EEA data to Israel We relies on the European Commission’s determination that Israel offers adequate data protection for transfers from the EEA.


Contact Us
If you have questions about the privacy aspects of our Sites or Services, please contact us at:

FORTVISION LTD
88 HaHashmonaim St.
5th Floor
Tel Aviv, Israel
+1.929.2439723
support@FORTVISION.com

Residents in the European Economic Area, if you wish to escalate your inquiry after contacting the support team, you are welcome to contact our Data Protection Officer at DPO@FORTVISION.com.




This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on our Sites. If we make any changes to this Privacy Policy that materially affect our practices with regard to the Information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites. We will seek your prior consent to any material changes, if and where this is required by applicable data protection laws.
If you have any questions about this Policy,
please contact us at info@FORTVISION.com
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