Last Updated: July,2022
In the event you are a California resident and the CCPA applies to you – please make sure to review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA.
DATA CONTROLLER & DATA PROTECTION OFFICER:
Telavi Ltd. incorporated under the laws of Israel is the controller of your Personal Data.
You may contact us and our privacy team as follows:
- Through the “Contact Us” feature available in the App
- By Email: email@example.com
- By Mail:
Shoham Street 2
Ramat Gan 5251003
THE DATA WE COLLECT & OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA
Depending on your interaction with us, meaning if you browse our site, install the App or if you register and use the Platform or Services, Tetavi collects two types of data:
Meaning, information which does not identify a specific natural person and cannot reasonably be used for such identification. We collect Non-Personal Data regarding use of the Services, such as the scope, frequency, latency, pages accessed and viewed, time and date you have accessed the Services, interactions with content and materials displayed through our Services, language preference, and other technical information regarding the device used to access the Services, for example type of device, type of browser, operating system, etc.
Non-Personal Data is used mainly for click stream analysis in order to maintain and develop our Services, including among others, in order to measure and understand the level of engagement with the Services, for general business analytics for ensuring the technical functioning of our network, to help prevent fraudulent use of the Services and for developing new Services and features.
Meaning, information which identifies or can be reasonably used to identify an individual, and for example your name, phone number, email address, pictures, unique online identifiers etc.
The table below details the processing of Personal Data, the purpose, lawful basis and processing operations:
PURPOSE AND OPERATIONS
If you voluntarily contact us in order to ask a question, to schedule a meeting or other inquiries (including through form available on our site) you may be required to provide us with certain information such as your name and email address (“Contact Information”).
We will use this data to provide you with the support you requested or to respond to your inquiry.
We process such Contact Information subject to our legitimate interest in order to respond to your inquiry.
If you participate in our survey, you will be required to provide certain information such as: age, phone number, mail address, name and your feedback.
We will use this data and information in order to improve and enhance our App and Services
We process this information based on your consent provided when you participate in the survey.
We may use the email address provided by you for direct marketing, meaning we will send you email promotions and updates specifically regarding the Services you are interested in (“Direct Marketing”).
We process such Contact Information subject to our legitimate interest in order to contact you with updates and offers relating to our Services that we believe might interest you.
You may opt-out at any time by contacting us at firstname.lastname@example.org or by other means we will make available (e.g., “unsubscribe” link within the applicable email).
If you choose to register and to create an account and profile, you will be required to provide us with your mobile number, account login details (such as your username and password which you have chosen) and you may choose to provide us with your photo as well (“Account Data“).
To verify the authentication of your account and details, we may ask to send you a verification code, for this purpose we will use the phone number you provided.
We use this data to create your account and profile, enable the Services and for verification and authentication.
Our lawful basis for the collection and processing of the Account Data is the performance of our contract with you – meaning, to create and administrate your account and profile, in order to enable you to use our Services, all in accordance to the Terms.
We rely on our legitimate interest where we use your phone number in order to authenticate and verify your identity, as well as to make sure you do not already have an account, including, in order to send you a verification code once you sign up, as well as to send our users operational notifications, including push notification through the App.
Online Identifiers, meaning online identifiers associated with the device or browser you have used to access our Services, including IP address and Cookies ID (“Online Identifier”).
We process such data when you browse our site through third party cookies for analytic purposes and to operate, manage and improve the Services.
We process this information based on your consent provided when signing up to the app.
User-generated content, such as photos and videos uploaded or created by you through the Services or comments you post through the chat available on our Platform (“UGC”).
If you choose to include Personal Information within the UGC, such UGC may be displayed or Shared through the Services and may be used by other users of the Services, including through external social media networks (such as Facebook, Instagram, tiktok, Twitter, etc.).
Our lawful basis for the collection and processing of the UGC is the performance of our contract with you – meaning, to provide and deliver our Services, including, enabling users to create UGC, upload and share UGC through the Services
Android access permissions (“Permissions”):
The Permissions are used for the following purposes:
To access these Permissions, you will need to affirmatively enable them through an in-app permission or the mobile settings. You may disable the Permissions at any time, but depending on the Permission you disable, a feature or all features may not function properly.
In order to provide the Services, we use face recognition technology to recognize faces in videos and we may detect and use facial marks to provide facial manipulation features (“Facial Information”).
The Facial Information we collect cannot be used for identifying a specific person at all, and is used to provide the mentioned features only.
When the user closes the application, the facial mapping information is discarded. This information is not shared with any third parties.
We will neither use the results for other purposes nor upload data to our servers.
Our lawful basis for the collection and processing of the Facial Information is the performance of our contract with you – meaning, to provide and deliver our Services, including, enabling users to create and edit videos.
In the event you apply for a job via our Site, we will collect your CVs and additional information such as your contact details.
To process your job application and for recruitment purposes.
Our legitimate interest.
If you wish to purchase or sell a video, you will be required to provide us with payment information, such as your card or bank account details, name, address and etc. (“Payment Information”)
Processing the payment in order to enable user to sell or purchase videos through the Platform.
Payments made by users will be processed by a third-party payment processor.
We won’t process any Payment Information, we will be using a third party payment processor which will be bound by a data processing agreement with us.
HOW WE COLLECT YOUR INFORMATION?
We collect the above data from you, in the following ways:
- When you voluntarily choose to provide us with information, e.g., when you contact us.
- Automatically, when you use our Services, for example, when you use the site or App, such as analytics.
Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may remove cookies by following the instructions in your device preferences (as detailed below). However, please note that if you choose to disable cookies, some features of the Services may not operate properly and your online experience may be limited.
Types of cookies used on our website:
The following are the types of cookies that we use on our Services:
- Essential, Functionality, Operation, and Security Cookies. These cookies are essential for enabling users’ navigation of the Services, for the Services to function properly, and for security purposes (e.g., to prevent fraudulent use). This category of cookies either cannot be disabled, or if disabled, may result in certain features of the Services not working or functioning properly.
- Analytic, Measurement and Performance Cookies. These cookies are used to collect information about how users use our Services, in order to improve our services and the way we offer them, as well assess performance of the Services and the way it is displayed on our Services.
We use the following third-party cookies and SDKs on our Services:
Analytic, Measurement & Performance Cookies
Share on social networks
Share on social networks
You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings.
Please note that once you choose opt out, part of the services and content on the Services provided by us may no longer be available, and some features may not work if you revoke the data transfer. In addition, even if you do opt-out, you may still receive some content and advertising, however, it will not be targeted content or advertising.
DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
Tetavi will share Personal Data with third parties, mainly for the purpose of the operation of the Services, as well as to improve, protect and advertise the Services. The circumstances, in which Tetavi will share your Personal Data, as well as the categories of such third-party recipients, are as follows:
- Tetavi’s Service Providers – we will share Personal Data with our service providers that perform business operations on our behalf, including data storage providers, customer support providers, data analytics and data management providers and data security providers. When we do so, we ensure that the service providers only have access to such information that is strictly necessary in order for us to provide the Services. The service providers are required to secure the received data, to use it for pre-agreed purposes only and to ensure compliance with all applicable data protection regulations.
- Legal and Law Enforcement. We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose Tetavi or its users to legal liability, and solely to the extent necessary to comply with such purpose.
Other third parties with your consent to do so. However, when we share your information based on your consent, following such disclosure, the shared information will be subject to such third party’s privacy practices which might differ from our practices detailed herein.
In addition, please note that when you share content on the Services, including UGC through the chat at the Platform, such content and your interaction with it will be publicly shared through the Services and might be shared by other users outside our Platform.
RETENTION AND SECURITY OF DATA
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable.
The criteria used by us to determine our retention periods are as follows:
- We retain Personal Data for the periods needed in order to achieve the purpose for which Personal Data was collected. For example, Personal Data required to be retained in order to maintain your account and to enable you the use of the Services (such as, mobile number and email address) or Personal Data you have voluntarily provided during registration or operation of your account (such as photo, username, UGC, etc.) will be retained for as long as you maintain your account. Note that, upon deletion of your account, your UGC will be deleted from your account; however, it may retain by other users we do not control any third-party platform in which the UGC was published by you, other users or any third party.
- We retain Personal Data for the periods needed in order to comply with our obligations under applicable laws.
- If you have a dispute with us, we may retain certain types of Personal Data as necessary and applicable to your claims, including any legal proceedings between us, until such dispute was resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the applicable correspondence for as long as needed to demonstrate compliance.
We may at our sole discretion, rectify or erase information from our systems, without prior notice to you, once we deem it is no longer necessary for such purposes.
We take great care in implementing physical, technical, and administrative security measures that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost. You need to remember, however, that unfortunately, the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the full security of data transmitted via our website, and any transmission of your data shall be done at your own risk.
We may store or process your Personal Data in a variety of countries, including Israel. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area (“EEA“) is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union.
Our Services is not directed nor is it intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law which with respect to the EEA is under the age of 16 and with respect to the U.S.A, under the age of 13) and we do not knowingly process a children’s information. We will discard any information that we receive from a user that is considered a “child” immediately upon our discovery that such a user shared information with us. Please contact us at: email@example.com, if you have reason to believe that a child has shared any information with us.
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information. Depending on your relationship with us, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination and the right to cease sharing or selling your information as such term is defined under the California Privacy Regulations such as the CCPA (as further detailed in the CCPA Notice).
Further, certain rights are available within the App: you may correct, revise and delete information from the App settings at any time, any consent provided may be easily withdraw, therefore we recommend you use the technical solutions we have provided you with to exercise your rights.
CHANGES AND UPDATES