Privacy Policy

Phloc’s Privacy Policy – 16/11/2020

Last Revised: November 16, 2020.

Great Experience Group Ltd. (“GEG” or “we”), Israeli private company no. 515975068, of Bar Hofman 3/51,  6811917, Tel Aviv, Israel, is the owner and operator of the phloc website, https://www.phloc.io (the “Site”). The Site generates content and experiences in the field of photography, and provides a platform for its users (persons, entities or businesses), to connect with photographers. The Site further provides a platform enabling users (persons, entities or businesses) to host and guide the experiences (online hands-on workshops and/or online series and / or webinars relating to photography), to share  pictures / images with other users (Guides / Phlocal), via affiliated sites (e.g. Miro), to have them reviewed by other expert photographers (persons, entities or businesses), and to receive feedback, critiques, and/or recommendations from other expert photographers (“Phlocals“) with respect to the user’s pictures / photographs / images (via one-on-one or one-on-many online sessions – the “Sessions“).

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 when booking an experience, 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 Share With Us : In the framework of the Website’s Services, you may share certain Personal Information (relating to your personal data, photography experience, photos / images you share with us, etc.). Certain information shall be mandatory to share, in order to offer or book Services on the Website.

3.2.3      Personal Information Collected from Other Users: In the framework of the Website’s Services, we may enable customers to provide reviews and rankings as to the Services provided by our affiliates / service providers, and to indicate their level of satisfaction following any online experience. Such reviews and rankings may, at the Company’s sole and absolute discretion, be saved by the Company, and may be presented on the Company’s website and/or on other platforms.

3.2.4          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 share while booking phloc experiences, and any all photos which you share with us in the framework of the booking process, or thereafter.

4.3 We collect certain information from other Users of the Site, e.g. reviews and rankings provided by the Customers as to the Services provided by our affiliates / service providers.

4.4 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.
  • Enable direct contact between GEG and the users, including, without limitation, sending reminders regarding the Services which are booked, contacting the user with respect to the sharing of photos (prior to the booked Session), provide the user with technical directions, and contacting the user after the Session, in order to send certain results / reports to the user.
  • Provide a rating / ranking system on the Site, for our affiliates / service providers. Such ranking and rating may be presented on the Site, in order to enable other customers to choose their preferred service provider.
  • Enable the completion of transactions, and enable payments to be made with respect to the Services provided over the Site.
  • 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 phlocal 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;
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 your availability information with other users of the Site, in order to book your Session. In addition, we may share your ratings / ranking with potential customers, in order to enable them to choose their preferred service provider.
  • 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 Information to 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.