FORTVISION PRIVACY POLICY
Effective date: Jan 02, 2020
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, Bloggers, eCommerce, Brands, Advertisers, App developers, any SMB site or mobile native app (“Customers”) can create, embed and share interactive content units, including but not limited to: quizzes, questionnaires, feedback applications, chat-bots, lead forms, videos, image galleries or other features ("Service"), that can be distributed and offered on their website, application, emails, sms, 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. The end-users who are exposed to FORTVISION content is called "Users".

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 along with email opens. 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; (iv) engagments with emails sent from FORTVISION platform. 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. For example, we will collect a Customer's contact details when a Customer enters a contractual relationship with FORTVISION and we will collect a username and password when a Customer creates an account on any of our Sites. 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 or form that a Customer submits through our Sites or via email. We may also collect Information from prospective customers through publicly-available sources.

When a Customer signs up to use our Services or uses FORTVISION platform, we collect Information such as the Customer's name, email address, telephone number, payment card information, billing information, and any other Information the Customer may choose to provide to us on the platform. We may also work with third party vendors to process payments to or from our Customers on our behalf. These vendors currently include Stripe and Paypal, but are subject to change at any time. We do not have access to the Information that you provide to these third parties, and we encourage you to visit their privacy policies to understand their practices.

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).


How We Use Customer Information
We use Customer Information for the following purposes:

Providing our Service.
We use Customer Information to provide our Sites and Services and for other customer service purposes in relation to Customer accounts.

Communicating.
We use Customer Information to communicate, via email or otherwise, about Customers’ accounts; to contact Customers about new products or services that we think may interest you; to respond to Customer inquiries, requests, or complaints; and to provide Customers with product updates, news, best practices, and other helpful or interesting information that can enhance your use of FORTVISION platform, 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 to measure Customer engagement. For more information about cookies, please see our Cookie Policy.

Marketing and advertising.
We use Customer Information to provide Customers with newsletters, special offers, and promotions, including via email; and for other marketing, advertising, and promotional purposes, including general updates about FORTVISION. These communications will be sent in accordance with our Customers' communications preferences.


How We Disclose Customer Information
We may disclose Customer Information as follows:

Affiliates.
We may disclose Customer Information to any of our current or future affiliates (affiliates are companies controlling, controlled by, or under common control with us, parent companies, or subsidiaries to process for the purposes described in this Privacy Policy.

Service providers.
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.

Customers.
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 their campaign have appeared on.


Customer Choices
Customers may access, correct, or update the Information that they have provided to us by either updating the Information in their account, by emailing their dedicated account manager, 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 ten (10) business days for us to process opt-out requests. If you opt out of receiving marketing and advertising emails from FORTVISION, we will still send you emails about your account and any Services that you have requested or received from us.


Users
Information We Collect from Users (“User Information”)
We automatically collect User Information when Users interact with our Services that appear on our Customers' websites and digital properties. Like most other web-based services, 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), 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.
All data gathered during an advertising campaign is owned by the advertiser and FORTVISION will keep the primary (row) data until the campaign ends. Aggregated data will be kept even after the campaign ends.

For more information about how we use cookies and other technologies, please refer to our Cookie Policy.


How We Use User Information
We use User Information for the following purposes:

Providing our Service.
We may use User Information to provide our Services to Users and our Customers.

Tailoring content.
We may use User Information to tailor the content and information that we may send or display to Users; to retarget content to Users through our Services and elsewhere; and to otherwise personalize your experiences while using our Services. For more information about how we tailor our content see information below about our Interest Based Advertising.
We may use User Information to improve a unique User’s experience across multiple browsers and devices (such as smartphones, tablets, or other viewing devices) by providing better targeted ad campaigns to that User. For instance, should 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 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 target the right audience.

Offering our Customers data segments
A data segment is a grouping of users who share one or more attributes. We offer a number of data segments to our Customers so that they may better target Users. FORTVISION 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 or your religious affiliations, or Personal Data concerning your sensitive health information, sex life or sexual orientation, or genetic or biometric data). However, in connection with our Services, our Customers may use these standard health-related segments about non-sensitive conditions such as an inferred interest in health and wellness or over the counter medications.


How We Disclose User Information
We may disclose User Information as follows:

Affiliates.
We may disclose User Information to any current or future Affiliates, parent companies, or subsidiaries to process for the purposes described in this Privacy Policy.

Service providers.
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. Unaffiliated third parties. We may disclose User Information to other unaffiliated third parties, specifically with (i) our data partners, so that we can connect you with relevant content by allowing our advertisers to target specific audience segments, and (ii) our programmatic demand and supply partners.

Customers.
We may disclose User Information to Customers where relevant to the Service we provide those Customers. For example, we may provide eCommerce site with information about the viewing and click-through patterns of the products they publish and may provide them with information about conversion rates for analytics purposes, poll or chat-bot engagments, etc.


Accessing Your User Information
You have the right to request that FORTVISION provide you with 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.


Interest-Based Advertising
Through our Services, including our Services on Customer websites, we may provide advertisements (and other content that meant to increase your engagment with the site) to you based on your recent browsing behavior across different Customer websites, browsers, or devices. For example, if on a first online visit, you browse on website A, then on a subsequent visit to website B, you may see content personalized based on your browsing history on website A. For example, if a user visits a sports site, he might see mens' products on an eCommerce site he visits.
In order to target advertisements to you for products and services that may interest you, 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.

If you have questions about our collection and use of data for interest-based advertising purposes, please contact us at: support@FORTVISION.com.


User Choices and Opting Out
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.
If you do not want to receive interest-based content, you can disable the display of such ads by clicking on the opt-out button below. Please note that an opt out will not prevent you from seeing the Service. Rather, the opt out will prevent us from using your Information. You will continue to get our Service based on the particular website that you are viewing.

Opt-out

Please also note:
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.
We may use non-cookie technologies in limited cases. Like cookies, these technologies allow us to remember whether you have chosen to opt-out from our Services. Please note that some web browsers may not permit you to block the use of non-cookie technologies, but you can do so by simply clicking on the Opt Out feature above.
You may use the NAI opt out tool , which will allow you to opt out of receiving targeted ads from FORTVISION and from other NAI-approved member companies. The NAI also provides instructions to engage system-level mobile device opt outs in Android, iOS, and Windows Phone environments.

You may also visit one of the Digital Advertising Alliance affiliate websites to learn more about User choices and opting out of interest-based advertising displayed by the many member companies.
Users in the United States may visit the DAA consumer choice page at www.aboutads.info/choices
Users in Canada may visit the DAAC consumer choice page at www.youradchoices.ca/choices
Users in Europe may visit the EDAA consumer choice page at www.youronlinechoices.eu

Please note that an opt out from one or more companies listed on the DAA, DAAC, or EDAA consumer choice pages will not prevent you from seeing those companies’ advertisements. Rather, the opt out will prevent these companies from using your Information to display targeted content or ads to you. You may continue to receive advertisements that are selected based on the particular website that you are viewing (i.e., contextually based ads).

Also, if your browsers are configured to reject cookies when you visit the DAA, DAAC or EDAA consumer choice pages, your opt out may not be effective because your browser will refuse opt-out cookies (that alert companies that you have exercised your opt-out preference).


Data Retention
We retain User Information for at most thirteen (13) months from the User’s last interaction with our Services (often for a shorter period of time), 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 your opt-out requests.


Children
We do not knowingly collect any data on websites directed to children under the age of sixteen (16). If you are the parent or guardian of a child under the age of sixteen (16) and have a concern regarding the Information we collect, please contact us at privacy@FORTVISION.com.


Site Visitors
Information We Collect from Site Visitors
FORTVISION collects Site Visitor Information directly from you during your use of our Sites.

Information we collect directly from you.
We may collect Site Visitor Information directly from you. For example, when you send us an email asking a question, when you interact with our chat-bot, poll, story or any any format, or submit a form on our Sites to receive marketing materials or email newsletters, we will collect the Information that you submit to us. We may also use third party analytics scripts to record your input of data into these fields before it is submitted. We may also collect any other Information that you choose to provide to us, such as the contents of a message that you submit through our Sites.
We may collect Site Visitor Information about you. Such information may include, without limitation, information about your operating system, IP address, settings and system configurations, device model, device ID and other unique device identifiers, mobile related information, the web pages you access within our Sites, the website that led you to our Sites, the website to which you go after leaving our Sites, the dates and times that you access our Sites, event information (e.g., system crashes) and web log data.


The Personal Information that we may collect or receive about you broadly falls into the following categories:
Information we receive about Contacts from our Users:
A Member may provide Personal Information about you to us through the Service. When a Member uploads their Distribution List or integrates the Service with another website or service (for example, when a Member chooses to connect their e-commerce account with FORTVISION), or when you sign up for a Member’s Distribution List on a FORTVISION or other signup form, the Member may provide us with certain contact information or other Personal Information about you such as your name, email address, address, or telephone number. You may have the opportunity to update some of this information by electing to update or manage your preferences via an email you receive from a Member.

Information we collect automatically:
When you interact with an email campaign that you receive from a Member or browse or purchase from a Member’s connected store, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below and in more detail in our Cookie Statement available here.
Device information: We collect information about the device and applications you use to access emails sent through our Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
Usage data: It is important for us to ensure the security and reliability of the Service we provide. Therefore, we also collect usage data about your interactions with campaigns (and/or emails) sent through the Service, which may include dates and times you access campaigns (and/or emails) and your browsing activities (such as what pages are viewed and which emails are opened). This information also allows us to ensure compliance with our Standard Terms of Use and Acceptable Use Policy, to monitor and prevent service abuse, and to ensure we attain certain usage standards and metrics in relation to our Service. We also collect information regarding the performance of the Service, including metrics related to the deliverability of emails and other electronic communications that our Users send through the Service. This information allows us to improve the content and operation of the Service and facilitate research and perform analysis into the use and performance of the Service.

Information we collect from other sources:
From time to time, we may obtain information about you from third-party sources, such as social media platforms, and third-party data providers. We use this information to provide publicly available social media information about you to Users who have enabled the "Social Profiles" feature in their FORTVISION accounts.



How We Use Site Visitor Information
We use your Site Visitor Information for the following purposes:
Providing our Service.
We use Site Visitor Information too provide and manage our Sites and Services.
To protect the rights and safety of Users, third parties, or FORTVISION. For example, sometimes we review the content of our Users’ email campaigns to make sure they comply with our Standard Terms of Use. To improve that process, we have software that helps us find email campaigns that may violate our Standard Terms of Use. We, or our third-party service provider, may review those particular email campaigns, which may include your contact information. This reduces the amount of spam being sent through our servers and helps us maintain high deliverability.
To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
To prosecute and defend a court, arbitration, or similar legal proceeding.
To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
To carry out other business purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.

Personalization
We use Site Visitor Information to personalize the expeirnce and information that we send or display to you on our Sites.

Communicating with you.
We use Site Visitor Information to communicate with you, including via email, about our Services; to respond to your inquiries via our website request forms; and to answer any questions or complaints you submit; to provide you with news, best practices or other information that we think may interest you.
To provide, support and improve the Service. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to our Members. When we share Personal Information with third parties, we take steps to protect your information in a manner that is consistent with applicable privacy laws.

Marketing and advertising.
We use Site Visitor Information to provide you with newsletters, special offers, and promotions, including via email; to contact you about products or services we think may interest you; and for other marketing, advertising, and promotional purposes. These communications will be sent in accordance with your communications preferences.

Analyzing use of our Sites.
We use Site Visitor Information to better understand how individuals access and use our Sites, both on an aggregated and individualized basis; to honor their requests and preferences; and for other research, analytical or statistical purposes.



How We Disclose Site Visitor Information
We may disclose Site Visitor Information as follows:
Affiliates.
We may disclose Site Visitor Information to any current or future Affiliates, parent companies, or subsidiaries to process for the purposes described in this Privacy Policy.

Service providers.
We may disclose Site Visitor 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.


Site Visitor Choices
Site Visitors may opt out of the FORTVISION platform that collects information on the Sites.(California Site Visitors may exercise their options directly with FORTVISION). By visiting one of the Digital Advertising Alliance affiliate websites, you can learn more about User choices and opting out of interest-based advertising displayed by the many member companies.

Users in the United States may visit the DAA consumer choice page at www.aboutads.info/choices,
Users in Canada may visit the DAAC consumer choice page at www.youradchoices.ca/choices
Users in Europe may visit the EDAA consumer choice page at www.youronlinechoices.eu
Please note that an opt out from one or more companies listed on the DAA, DAAC, or EDAA consumer choice pages will not prevent you from seeing those companies’ advertisements. Rather, the opt out will prevent these companies from using your Information to display targeted content or ads to you. You may continue to receive advertisements that are selected based on the particular website that you are viewing (i.e., contextually based ads).

Also, if your browsers are configured to reject cookies when you visit the DAA, DAAC or EDAA consumer choice pages, your opt out may not be effective because your browser will refuse opt-out cookies (that alert companies that you have exercised your opt-out preference).

For Site Visitors who have subscribed to receive emails from us, you can manage your subscription by clicking your unique link that appears at the bottom of each of these emails.


General provisions applicable to Customers, Users and Site Visitors
How We Use Your Information
We use the Information that we collect from Customers, Users, and Site Visitors for the purposes respectively set forth in Sections above, as well as for the following purposes:

Analyzing use of our Services.
We use the Information that we collect to better understand how Customers, Users, and Site Visitors access and use our Site and Services, both on an aggregated and individualized basis; to respond to Customers’, Users’, and Site Visitors’ requests and preferences; and for other research, analytical, and statistical purposes.

Legal compliance.
We use the Information that we collect to comply with applicable legal obligations, including requests from law enforcement or other governmental entities.

Protecting our rights and interests.
We use the Information that we collect to protect our rights and interests and the rights and interests of our Customers, Users, Site Visitors, 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.

In addition to the disclosures detailed above, we may also disclose Information for the following purposes:

Business transfers.
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, if we undergo a bankruptcy proceeding, or if we engage in any other similar business transfer. Legal compliance. We may disclose Information in order to comply with the law, regulation, a judicial proceeding, subpoena, court order, or other legal process.

Protecting rights and interests.
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.

Aggregate and de-identified Information.
We may disclose to our Customers and other third parties aggregated or de-identified information about users for marketing, advertising, research, or other purposes.


Cookies and Other Tracking Mechanisms
For more information about how we use cookies and other tracking mechanisms on the Sites and when providing our Services, please refer to our Cookie Policy. You may disable certain tracking as discussed in our Cookie Policy (e.g., by disabling cookies).


Third-Party Links
Our Sites and Services may contain links to our third-party partners’ 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.
For example, our Sites include features from third-party social networking platforms, such as the Facebook “Like” button. 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, Google Cloud 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.
We may transfer your Information outside the country in which it is collected, including to a country that may not offer the same level of protection for Information as the country in which you reside. Rest assured however, that FORTVISION has arranged all contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among our Affiliates, subsidiaries, and/or parent companies.


Regional Privacy Rights
Notice to Individuals within the European Economic Area (“EEA”)
If you reside in the EEA, We will be the controller of your Personal Data provided to, collected by or for, or processed by FORTVISION in connection with our Services.

If you are a Customer, Site Visitor, or User from the European Economic Area, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
However, we will normally collect Personal Data from you only (i) where we have your consent to do so, (ii) where we need the Personal Data 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 Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.
If we ask you to provide Personal Data 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 Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
Similarly, if we collect and use your Personal Data 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.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, please contact us as specified in section below.

You have the right to request that FORTVISION (i) provide you with access to the Personal Data we hold about you, (ii) correct your Personal Data, (iii) delete your Personal Data, and (iv) cease or restrict processing of your Personal Data. If you are a User and would like to understand what Personal Data and behavioural information FORTVISION holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data. Customers may also submit a data subject access request by emailing us at privacy@FORTVISION.com so that FORTVISION may either respond with the relevant information or, if applicable, direct this request to, and cooperate with, your employer to respond.
You have the right to complain to a data protection authority about our collection and use of your Personal Data. To learn more, please contact your local data protection authority, via the contact methods available here. However, if you have any questions about our collection and use of your Personal Data, 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.

FORTVISION transfers data outside the EEA. FORTVISION relies on adequacy determinations, because data is controlled and stored by FORTVISION's Israeli entity. In addition, FORTVISION also has in place an Inter Group Data Transfer Agreement across its international entities, which is based on the standard model clauses.
As part of FORTVISION’s global operations, our data flows between the EEA, the United States and Israel. To ensure that EEA Data is adequately protected when transferred outside the EEA, the Data Protection Directive 95/46/EC and the General Data Protection Regulation mandate that such transfers take place using certain legal mechanisms.
When transferring EEA data to Israel, FORTVISION relies on the European Commission’s determination that Israel offers adequate data protection for transfers from the EEA. When transferring EEA data elsewhere, FORTVISION relies on the European Commission’s approved Standard Contractual Clauses, which are contractual privacy and security commitments between companies that transfer personal data. FORTVISION and its Affiliates have accordingly adopted Standard Contractual Clauses to ensure the legality, privacy, and security of the data flows necessary to provide, maintain, and develop our services.


Your Rights to Your Personal Information
California residents have the right to request that FORTVISION (i) provide you with access to the Personal Information that we hold about you, (ii) correct your Personal Information, (iii) delete your Personal Information, and (iv) cease or restrict disclosures or sales of your Personal Information to third parties. You also have a right against descrimination for exercising any of these rights, which FORTVISION is committed to upholding and honoring at all times.
If you would like to opt out of FORTVISION’s disclosures and sales of your Personal Information, you may do so as outlined in FORTVISION’s California Consumer Rights Portal. Please note that this feature is currently only available for California state residents.


Categories of Data
As mentioned above, FORTVISION maintains data about you in only pseudonymized form, which means that we do not know your identity because we do not process your name, email address, or other identifiable information. Instead, we only process digital identifiers such as cookie IDs, IP addresses, mobile advertising IDs on your device, FORTVISION network browsing history and associated preferences, and in some limited circumstances, your hashed email address and other data the user given acknowledge.


Where FORTVISION Collects Your Personal Information
We automatically collect User Information when Users interact with our Services that appear on our Customers' websites and digital properties. Like most other web-based services, we collect this User Information through cookies and other technologies. We may also obtain Information about you from our data partners.
FORTVISION collects Information either directly from you during your use of our Sites and Services or from third parties that independently collect this Information from you, and we may combine the Information that we collect from these various sources.


How FORTVISION Shares Your Personal Information
FORTVISION may disclose or make available your pseudonymous Personal Information to our trusted partners. In most cases when we do so, we have contractually restricted their uses of this data for only FORTVISION’s business purposes. Under the CCPA, such disclosures of Personal Information to service providers are not deemed to be a “sale” and thus are not prohibited after you exercise your right to cease or restrict disclosures or sales of your Personal Information to third parties. In any instances where we have not entered into a service provider relationship with such third parties, we will stop sharing your Personal Information when you instruct us not to “sell” your Personal Information.


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
+972.52.3361620
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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