Privacy Policy

Last Revised: August 8th, 2019

Great Experience Group Ltd. (“GEG” or “we”), Israeli private company no. 515975068, of Ben Yehuda 183, Apt 7, Tel Aviv, Israel, is the owner and operator of the phloc website, https://www.phloc.io. GEG respects the privacy of its website users (“User” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our primary website at https://www.phloc.io/ (the “Site”). Please read the following carefully to understand GEG’s views and practices regarding your personal information and how GEG will treat it.

  1. Application of this Privacy Policy

This Privacy Policy applies when you visit our Site. It also applies where we are in contact with you in other ways whether in your capacity as an individual or as a representative of a company or other organization.

  1. Your acknowledgment of this policy

This Privacy Policy (“Privacy Policy”) details how your Personal Information collected via the Site is used and processed by GEG.

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED) TO THIS PRIVACY POLICY AND GEG’S PRACTICES DESCRIBED THEREIN, INCLUDING THE PROCESSING (INCLUDING COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR INFORMATION UNDER THE TERMS OF THIS POLICY.

  1. Which information may we collect about Users? 

We collect from Users of our Site, two types of data and information:

3.1 Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).

You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site, the activities of the User on the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers such as Google Analytics and Hotjar to obtain detailed analytics on the device and the User’s behavior on the Site.

Please note that we or our third party service providers will collect such Technical and Behavioral Information by using certain technologies such as Cookies.

3.2 Personal Information. The other type of information we collect is individually identifiable information. This information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:

3.2.1      Personal Information which is provided voluntarily:

  • Direct Communications with GEG: Personal Information you provide us as part of any communications with GEG, by any means, including, without limitation, information you send to us in the framework of your registration process to the Site, information delivered to us when the user approaches our customer services or during sales calls (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences).

3.2.2      Personal Information Which You Upload to the Website: In the framework of the Website’s Services, you may upload certain Personal Information (relating to you personal data, photography experience, etc.). Certain information shall be mandatory to upload, in order to offer or book Services on the Website.

3.2.3      Personal Information collected via technology:

  • Geolocation data: while using the Site we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of IP addresses and other similar information to determine your location for analytics and security purposes. Please note that we may also analyze your IP address, using our third party service providers, in order to determine the name of the company whose IP address you have used to browse our Site, for the purpose of locating prospects and in order to analyze our Site’s traffic.
  • Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 3.1 will be linked to or associated with a specific individual then such information will be considered as Personal Information.
  • Identifiers: such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or another unique identifiers.

3.3 Please note:

  • We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
  • We use third-party tracking services and usage logs, to track and analyze data from Users of the Site and for purposes of security and fraud prevention.
  1. How do we collect information about our Users? 

There are three main methods we use to collect information:

4.1 We collect information through your entry, connection, access and/or use of the Site. When you access or use the Site we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.

4.2 We collect information which you provide us voluntarily. We will collect, inter alia, all information that you upload to the Website, as part of the registration, posting phloc experiences, booking phloc experiences, rating / ranking other Users of the Site, etc.

4.3 We collect information from public sources. We may supplement personal information that we collect about you with information which you have made public on websites associated with you or your company or on social media platforms such as LinkedIn, Facebook, etc.

  1. Cookies

5.1 We collect anonymous information through cookies. A cookie is a small piece of data containing a unique identification number that is sent to your browser from a web server, and is stored on your computer’s hard drive. The unique ID number identifies your browser to our computers whenever you visit. Cookies do not enable anyone to access personally identifiable information that you have not already given us. We primarily use cookies to connect members with account information stored on our computers. This helps us deliver better and more personalized services. We also use cookies to estimate our audience size for advertisers, to identify the specific services that you use, to hold session information and to track user preferences.

5.2 Cookies are part of the technology implemented by your browser. Most browsers are initially set up to accept cookies. You can reset your browser to either notify you when you have received a cookie, or to refuse them all together.

5.3 We rely on cookies to preserve the identity (profile) you have created while logged on. If you set your browser to disable cookies, you may not be able to access certain areas on the Website, or the Services, or the website and the Services may not recognize you.

  1. What are the purposes of the collection and processing of information? 

6.1 Non-personal Information is processed in order to:

  • Enhance the User’s experience on the Site;
  • Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features, experiences or locations are more popular than others); and
  • Keep the Site safe and secured and for prevention of fraud.

6.2 Personal Information is processed in order to: 

  • Enable the overall operation of the Site, and more specifically – enabling the phloc experiences to take place, by connecting the appropriate Guide (phlocal) with interested Guests.
  • Administer your Account;
  • To register your interest in becoming a Guest / Guide;
  • Enable the completion of transactions, and enable payments to be made with respect to the Services provided over the Site.
  • Enable Users to view ratings provided to other Users.
  • Contact you with further information relating to our products or services which you enquired about via the Site. To ensure we offer a good and responsive service, we consider this use to be proportionate and will not be prejudicial or detrimental to you;
  • Provide push notification with respect to the booking of any phloc experience in which you are a participant (either as a Guide or as a Guest).
  • Enable our third-party advertising Service Providers (as detailed below) to show GEG’s advertisements on websites across the Internet and across devices. You may opt-out such advertising activities by following the directions detailed in our Cookie Policy detailed in section 5 above.
  • Personalize your experience on the Site;
  • Ensure that content on the Site is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
  • Send you by email, SMS, phone, through web-browser notification or through the post updates, notices, announcements, and additional information related to GEG including with respect to changes made to our Site’s terms of use and privacy policy;
  • Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;
  • Keep the Site safe and secured and for prevention of fraud and crime;
  • Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site;
  • Maintain our data processing records and general administrative purposes;
  • Use the Personal Information included in the User’s profile, for GEG’s marketing purposes (e.g. publishing the ‘most popular experiences’ or ‘picture of the day’).
Note to our Users in the EU:

In order for GEG to process your Personal Information, as detailed herein, such processing must be justified by a “basis” for processing. Please note that the Personal Information processing activities detailed herein may be justified on the basis that:

·    the processing is based on your consent– where you provide us with your consent to contact you for marketing purposes or when we use cookies to collect information about your use of the Site, you will be asked to consent to such activities before we can process such information. If you choose not to give us your consent for such processing activities, or if you decide later to remove your consent, this may affect our ability to provide you with the services available on our Site;

·    the processing is necessary for performance of a contract or in order to take steps prior to entering into a contract – usually your Personal Information will be provided to us because you are interested in engaging with GEG for the purchase of our Services. As such, we rely on this basis for processing activities that are required in order to enable you to use the Site and to let you know of changes to our Site’s terms of use and privacy policy;

·    the processing is necessary to comply with a legal obligation – we may process your Personal Information for disclosure of information to authorities; and

·    the processing is in our legitimate commercial interests – subject to your interests and fundamental rights, under our legitimate interest in marketing our Services via the Site and offering the public comfortable and safe access to our Site, we shall perform the Personal Information processing activities described herein, such as the processing of your Personal Information in order to personalize the Site, assisting us to prevent crime and fraud, manage our internal operations, maintaining records and email tracking. Where we rely on legitimate interests as a lawful basis, we will carry out a balancing test to ensure that your interests, rights and freedoms do not override our legitimate interests.

Note to non-EU Users:

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION AS SPECIFIED HEREIN.

  1. Sharing Personal Information with Third Parties

7.1 GEG respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.

7.2 In addition to using the information collected by us for the purposes described under Section 6 above, we may also share your information in the following cases:

  • Providing the Site’s Services: In order to enable phloc experiences to take place, we will share all private information of phlocals with other Site’s Users (e.g. potential Guests), and we will share Personal Information of the Guests with the phlocals, immediately following the booking of a phloc experience.
  • GEG Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of GEG for the sole purpose of enabling the operation of the Site and to contact you (as detailed in Section 6 above). Please note that all GEG personnel that will have access to your Personal Information are under an obligation of strict confidentiality with respect to such Personal Information.
  • Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party’s cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction. For more information regarding our Service Providers, please refer to Section 11 below.
  • In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy or any other agreement or terms of service between you and GEG, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of GEG, its Users or the general public; and (e) when GEG is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of GEG (while such acquired company or investor may be located in countries outside of your jurisdiction).

7.3 For avoidance of doubt, GEG may transfer and disclose Non-personal Informationto third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.

  1. Your Rights

GEG acknowledges you have the right to access and change the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: contact@phloc.io and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.

Note to our Users in the EU: 

We hereby inform you of the following rights (by virtue of EU law), in respect of your Personal Information:

  • Right to access: you may have the right to request a review of your Personal Information held by GEG. We may refuse to comply with your access request if the request is manifestly unfounded, excessive or repetitive in nature.
  • Right to rectification: if the Personal Information processed by GEG is incorrect, incomplete or not processed in compliance with applicable law or this Privacy Policy , you may have the right to have your Personal Information rectified.
  • Right to erasure: under certain conditions, you may be entitled to require that GEG will delete or “block” your Personal Information (e.g. if the continued processing of those data is not justified).
  • Right to object to or withdraw consent: where that lawful basis for processing your Personal Information is either “public interest” or “legitimate interests”, those lawful bases are not absolute, and you may have a right to object to such processing. Where you object on grounds of legitimate interest, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. If the processing of your Personal Information is based on your consent, you have the right to withdraw your consent to such processing at any time.
  • The right to restrict processing – under certain circumstances, you may have the right to object to theprocessing of your Personal Information due to your particular situation.
  • Right to lodge a complaint: you have the right to lodge a complaint before the relevant data protection authority or supervisory authority of your jurisdiction.

        To exercise these rights, where applicable, please contact us by sending an email to: contact@phloc.io 

  1. Location of Your Data 

The information collected from you by GEG, as detailed in this Privacy Policy, may be transferred to, and stored at, servers which may be located in countries outside of your jurisdiction and in a country that is not considered to offer an adequate level of protection under your local laws. It may also be processed by GEG and its suppliers, service providers or partners’ staff operating outside your country.

GEG is committed to protecting your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps include putting in place data transfer agreements or ensuring our third-party service providers comply with GEG’s data transfer protection measures.

Note to our Users in the EU: 

If you are located in the EU, you have a right to request further information regarding the data transfer mechanisms used by us with respect to data transfers to third countries.

In order to keep your Personal Information safe, we apply strict safeguards when transferring it outside of the EA, which may include the following:

·    Transferring your personal information to countries approved by the European Commission as having adequate data protection laws, such as Israel;

·    Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high quality protection, with the recipients of your Personal Information;

·    Transferring your Personal Information to organizations that are Privacy Shield Scheme certified, as approved by the European Commission.

BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE SITE, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

  1. Minors

The Site is intended for Users over the age of eighteen (18). Therefore, GEG does not intend and does not knowingly collect directly Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Site.

  1. Third Party Service Providers and Third Party Software 

11.1                While using the Site we may be using third party service providers, who may collect, store and/or process your information, as detailed in this Privacy Policy.

11.2                Note, that we collect, hold and/or manage your Personal Information through GEG’s authorized third parties vendors of certain products or services (such as hosting cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.

11.3                Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction.

11.4                Such third parties service providers include without limitation the following categories of service providers:

Please read such third party service providers’ terms of use and privacy policies to understand their privacy practices.

  1. Links to Third Party Websites 

Certain links provided in the Site permit Users to leave our Site and enter non-GEG sites or services. Most of such linked sites and services provide legal documents, including terms of use and Privacy Policy governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information about you is being collected.

  1. External Payment Service Providers

At this point in time, we use Stripe Payment Services a third-party intermediary to manage payments on the Site. When you intend to enter credit card information on our Site, you will automatically be transferred to Stripe’s website, and be subject to their terms and conditions.

Stripe Payment Services shall hold and store that credit card information under its own policies and regulations.

GEG has no control over, and assumes no responsibly for, the content, privacy policies or practices of Stripe Payment Services. You use Stripe Payment Services at your own discretion and in compliance with the terms and policies of the respective Service.  Stripe Payment Services are an independent contractor and you will be subject to their relevant terms of use. Stripes terms of use are available at https://stripe.com/

GEG reserves the right to replace its third party payment intermediary at any time in the future. In any such event, any payment you make shall be subject to such third party’s policies, terms and conditions, and GEG shall assume no responsibility for such third party’s actions.

  1. Security 

14.1 We take appropriate and reasonable measures to maintain the security and integrity of our Site and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.

14.2        Your Personal Information is currently hosted on Sharetribe  servers, which are located in Finland, and which provide advanced strict security standards (both physical and logical). Nonetheless, GEG reserves the right to transfer the database to another host company. In addition, Sharetribe may decide to host the database in other locations, as per Sharetribe’s privacy policy (which can be viewed at: https://www.sharetribe.com/privacypolicy.html).

14.3        Some of the security measures that we employ include, without limitation: restriction of access to your Personal Information to individuals who need access to it in order to process it on GEG’s behalf and implementation of a secured permission management and auditing system using specific and proprietary firewall and network access filtering as well as security group mechanisms.

Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.

14.4        GEG will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach if required by applicable law.

14.5        TO THE EXTENT THAT GEG IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, GEG SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.

 

  1. Data Retention 

GEG will retain the Personal Information for as long as we are comfortable that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

  1. Changes to the Privacy Policy 

The Company reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Site or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Site or sent to you via e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Site on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

  1. Have any Questions? 

If you have any questions (or comments) concerning this Privacy Policy, please send us an email to the following address: contact@phloc.io, and we will make an effort to reply within a reasonable timeframe.

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