Last Revised: August 5, 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 is an online platform enabling users to share pictures / images with other users (Guides / Phlocal), via affiliated sites (e.g. Miro), to have them reviewed by other expert photographers, 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.
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:
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 via technology:
3.3 Please note:
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 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.
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.
6.1 Non-personal Information is processed in order to:
6.2 Personal Information is processed in order to:
|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 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.
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:
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.
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: firstname.lastname@example.org 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:
To exercise these rights, where applicable, please contact us by sending an email to: email@example.com
|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.
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.
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:
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.
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 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.
14.3 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.
14.4 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.
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 it 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.