Zipory Ltd. (d/b/a “Keeprz”) was acquired by Conduit Ltd. (d/b/a/ “Como”) on October 13, 2015.

Please note that this End User Privacy Policy applies to: (a) your use of all App(s) created by using our DIY (do it yourself) solution and/or our CLM (customer loyalty management) solution (“CLM Solution”), and/or (b) when you join the Business’s customer membership club powered by our CLM Solution, whether you do so via the App or otherwise by offline means. Please note that certain features, services or capabilities may not be available on or supported by the App although governed by this Policy.

 

End User Privacy Policy

CONDUIT LTD., AND/OR ITS SUBSIDIARIES (DOING BUSINESS UNDER THE BRAND NAME: “COMO”) (“COMO”, “WE”, “US”, “OUR”), RESPECTS YOUR PRIVACY.

THIS PRIVACY POLICY (THE “POLICY”) EXPLAINS OUR PRIVACY PRACTICES FOR EACH OF THE MOBILE APPLICATIONS POWERED BY US THAT YOU DOWNLOADED AND THEIR RELATED SERVICES (TOGETHER REFERRED TO AS THE "APP"), THAT THE RESPECTIVE BUSINESS, VENDOR, OR ORGANIZATION (“BUSINESS”) HAS CREATED, CUSTOMIZED AND BRANDED.

This Policy describes the ways your personal information and data is collected and used and the rights and options available to you with respect to your information. You hereby agree to the use of: (a) electronic means to consent to and complete This Policy and to provide you with any notices given pursuant to This Policy; and (b) electronic records to store information related to this Policy and your use of the App.

This Policy is incorporated in the App's Terms of Use (the “Terms”).

Key Points:

The following key points of this Policy are brought for your convenience only. These key points do not substitute the full Policy.

Personal information that you voluntarily provide

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You may be asked to provide certain personal information upon (i) registering to or joining the CLM Solution, whether via the App, the Business’ website or via any other registration form; or (ii) upon registering to or joining certain activities, services or features provided by the CLM Solution, including via the App, such as reward programs or customer loyalty features (e.g. scratch card, point accumulation plans, punch card, coupons, gift card, cash back, “Pay with Budget”, “Frequent Buyer Club” or their equivalent, collectively hereinafterLoyalty Features”). This information is provided by you voluntarily and stored in our database. You may also upload photos to be shared with all other users of the App. [more]

Other Information collected

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While using the App, certain information is collected about your mobile device (such as your device identifier and IP address), as well the websites and content you have accessed, clicked or interacted with through your device. We may also collect info you uploaded by yourself to the App, as well as your physical address, geo-location information, phone number, name, date of birth, marriage date and various details and information from your social network account, should you choose to connect to your social account via the App. We may also collect information about the purchases you make in Business’s premises and items you order from the Business. [more]

Children's Privacy

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Personal information about children who are under 13 years of age is not knowingly or intentionally collected. [more]

Use of collected information

 

Your personal information is used to: provide you with the App’s functionality, features and services, customize the offers you receive from various businesses whose Apps you use, enable you to use such features and services on the App; send you App version updates and notifications; develop new services and for other ancillary purposes such as promotions and advertisement. [more]

Sharing and transferring collected information

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Your personal information is shared with the Business and/or with one of our business partners who is operating and administering the App on our behalf and on behalf of the Business (“Partner”). It may be shared with or transferred to others, to operate, maintain and enhance the App and any activity, feature and/or service provided to you via and/or on the App, to customize the offering of the App or through the App and for ancillary purposes. [more]

Aggregated or anonymized information

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Anonymized or aggregated information which does not identify you personally, may be collected through the App and used or shared for any purpose. [more]

Third party services, links and advertisements

 

Certain elements in the App are operated by E-commerce Providers or other third party providers, who are responsible for the privacy practices associated with such elements. The App may contain third-party ads and links that we are not responsible for. For more information, see the privacy policies of those third parties. [more]

Transfer of data outside your territory

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You grant us permission to store and process your personal information at locations outside your territory. [more]

Accessing or deleting personal information

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You may ask the Business to access or delete your personal information or send us an email request to access or delete the personal information collected through your use of the CLM Solution, including the App. [more]

Information Security

 

Information security systems and procedures are implemented, but they do not provide absolute information security. [more]

Changes to this Policy

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Any substantial changes to this Policy will be announced beforehand in one of two ways: either on our website or through the App. [more]

Contact Us

 

You may contact us by email. [more]

 

Personal information that you voluntarily provide

You may engage in certain activities provided or supported by the CLM Solution, including the App, such as: registration, request forms, signing-up for features, promotions, customer membership club, reward programs, Loyalty Features, scheduling services, newsletter, etc. When you do this, you will be asked to provide certain personal information, as determined by the Business (or businesses, if you downloaded several apps powered by us) or the third party providing such features, services and/or reward programs. This information is provided by you voluntarily and stored in our database.

Fields for mandatory completion will be explicitly indicated. If you do not provide the requisite data in these fields, you may not be able to register or engage in that specific activity, feature or service.

The App may also allow you to upload photos, in which case the photos you upload will be shared with and may be viewed by all other users of the App.

 

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Other Information collected

We collect information about your mobile device, such as your mobile device identifier (Android UDID and iOS UUID), the Internet protocol (IP) address your device uses to access the Internet, geo-location, your device type and its operating system version. We also collect information regarding the websites and content you have accessed, clicked or interacted with through the App as well as information regarding the interactions you make with the App’s interface such as your logging info, the App’s tabs, banners, or pages that you have clicked on or accessed, ads and/or promotions you have viewed through the App and receipt of notifications and/or SMS text messages sent to you through the App.

We may collect information regarding your participation in or use of certain Loyalty Features.

Other information such as purchase details (e.g., time and date of your purchase, place where purchase was made, the amount paid and information about the items purchased), may be collected while you use App features, when you make a purchase in Business’ premises or are located nearby the Business’s premises. We may use Beacons (as explained below) which are located in or nearby the Business’s premises in order to collect your (assumed) location.

A beacon is a device designed to attract attention to a specific location by using Bluetooth low energy signals (“Beacon”). Once your mobile phone device identifies a signal from a specific Beacon, the App will send such identification to our servers. By receiving such identification, we will assume that you are physically located in proximity of the location of that respective Beacon as registered in our database.

E-commerce Providers may be collecting additional information regarding your interactions with their systems. For information about their privacy practices, refer to their privacy policies.

When you place online orders through the App, we may collect information that you, or the E-commerce Providers choose to share with us. This information may include as your name, email address, shipping address, amount billed and information about the items ordered. We may use, share and transfer such information as described in this Policy. However, we do not receive or store the details of your credit card number. When using the “Frequent Buyer Club” feature, we keep in our records the 16-digit number of each Gift Card we provide to you, as well as information regarding the use made of such card.

By disabling your geo-location (through the mobile device operating system), certain features which require your geo-location information may not function or may be interrupted. Please note that by such disabling, your location may still be assumed and/or collected by us from other available sources as described here.

If you specifically opt-in to permit access and collection of information from your social network account(s), then your basic personal information in your social network account will be collected (such as your name, photo and email address) as well as your social network user ID (but not your password) and parameters related to the posts you shared through the App. Please refer to the social network’s privacy policy for more details on how you can set the privacy preferences of your account to control the information that may be accessed and retrieved.

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Children's Privacy

Personal information about children who are under 13 years of age is not knowingly or intentionally collected. If you are under age of 13 years, you are not permitted to register to any Loyalty Features, or use any aspect of the CLM Solution, including the App.

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Use of collected information

The information collected may be used for the following purposes:

·       Sharing it with or transferring it to others, as the case may be, as detailed in the next section ("Sharing collected information");

·       To provide you with the App’s functionality, features and services, send you, from time to time, push notifications, SMS text messages and/or commercial emails from the Business and other various businesses whose Apps you use and which are powered by us.

·       To remotely update the App on your mobile device when a new version is released;

·       To provide you with the specific and/or personalized activity, promotion, feature and/or service via the App and send you, from time to time, push notifications, SMS text messages and/or commercial emails regarding your use of such specific activity, promotion, feature and/or service; To provide you with offers and/or promotions from the Business which are based on your location as identified and collected by us (“Location Based Services”). Location Based Services may apply whenever your location is made available to us via your mobile phone operating system or from other available sources that we are connected with via our CLM Solution, such as purchases you make at the Business (or businesses if you chose to download several apps powered by us) premises, Beacons etc.

·       To improve and customize the experience of using the App and the offerings made through the App;

·       To develop new services;

·       To manage the administrative and operational aspects of our CLM Solution, including the App (such as Business and advertiser payments);

·       To enforce this Policy and the Terms and prevent unlawful activities and misuse of the App;

·       To comply with any applicable law and assist law enforcement agencies when we have a good faith belief that our cooperation with them meets the applicable legal standards; and

·       To take any action in any case of dispute involving you with respect to the App.

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Sharing and transferring collected information

The information outlined in the preceding sections, may be shared with, or transferred to others, as the case may be, in any of the following instances:

·       Registration information regarding the Business’ customer membership club, information on forms you have filled out and requests you have submitted which are intended for the Business – will all be shared with or transferred to the Business, for its own purposes;

·       Personal information from: your log in, registration to the customer membership club, will all be shared with the Business, for its own purposes.

·       We may share with the Business (or the Businesses, if you downloaded several apps powered by us), for their own purposes, information obtained from: your use or participation in the Business’ customer membership club, reward programs or other Loyalty Features, purchases you have made which are handled via the CLM Solution, including purchases made through the App (or Apps, if you downloaded several apps powered by us) or offline, items you order, and purchase invoices you submitted and uploaded to the App (or Apps, if you downloaded several apps powered by us).

·       Your purchase invoices may be also shared with third parties service providers, such as Amazon Mechanical Turk, in order to read and analyze the purchase invoices;

·       Information of the activities you scheduled via the App will be shared with Ping Up in order to provide you with scheduling services and with the Business, for its own purposes;

·       Photos you have uploaded through the App will be shared with all other users of the App as well as the Business;

·       Your location may be shared with the Business (or Businesses, if you downloaded several apps powered by us), for ad delivery and promotion purposes;

·       Information that we collect or obtain through the App may be shared with third parties such as service providers, to operate, maintain and enhance the App and our CLM Solution, and provide you with the App’s features and functionalities (such as online ordering, SMS text messaging, push notification);

·       If you have breached the Terms or this Policy, abused your rights to use the App, or violated any applicable law, or in any other case of dispute, or legal proceeding of any kind involving you with respect to the App, your information may be shared with competent authorities and with any third party, as may be required;

·       We may share information that we collect or obtain through the App with the relevant authorities, entities or persons if we reasonably believe that we are required by law to share or disclose your information;

·       Personally identifiable information may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly), but their use of such information must comply with this Policy; and

·       Information that we collect or obtain through the App may be shared with the respective Partner for its operation and administration of your App and executing Business’s and/or our requests with respect to the App functionality and respected services and/or features.

Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization in our ongoing business, the information that we collect or obtain, as outlined in the preceding sections, may be shared with or transferred to, that respective entity, provided that it undertakes to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, that entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and we will be released from any liability to you, regarding the succeeding entity’s use and processing of the information.

In any case other than the above mentioned in this Policy, your personally identifiable information will be shared with others only if you provide your consent.

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Aggregated or anonymized information

The App collects anonymized as well as aggregated information, which does not identify you personally. Such anonymized or aggregated information may be used in any way, including by posting, disseminating, transmitting or otherwise communicating or making it available to the Business, Partner as well as any other third party.

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Third party services, links and advertisements

You may be providing information through certain areas, features, frames or sections of the App, that are operated by or for third parties. Those third parties may include the Business from whom you may place certain orders, e-commerce platforms such as Amazon and Shopify, scheduling partners such as PingUp, and payment processing providers such as PayPal and Stripe (all collectively “E-commerce Providers”). In addition, E-commerce Providers may share with us information they collected from you or you voluntarily provided to them in accordance with their respective privacy policies. It is those E-commerce Providers, and not Como, that are responsible for the privacy practices associated with such elements. We encourage you to read the privacy policy of each E-commerce Provider.

It may happen that the App may contain or present advertisements (including banners) as well as links to third party websites. Advertisements may be facilitated by third party ad networks that serve advertisements originating from third parties, or by Como that serves advertisements or promotions regarding other mobile application generated or administered by Como. Though we collect certain parameters related to your interactions with advertisements (as detailed in this Policy), we are not responsible for the privacy practices of third party advertisers and ad networks, and this Policy does not apply to them. We are also not responsible for the privacy practices of third party websites that the App may contain links to. Please refer to the privacy policies of those advertisers, ad networks, and third party websites to determine whether their privacy practices are acceptable to you.

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Transfer of data outside your territory

The App, by its nature as an online service, may store and process information in Europe, the United States and in other various locations throughout the globe. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you hereby provide your express and unambiguous consent to such transfer.

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Accessing or deleting personal information

You may submit a request to us or the Business to access, delete or remove the personal information collected through your use of the App and/or the Business customer membership club. You may do so by contacting the Business directly via the App, its website or ask the Business to do so at its premises. You may also contact us via email. You may be asked to provide additional information to verify your identity. Note that the App or certain features or services of the App may not be available or function if such information is deleted or removed.

Be advised that information may still reside in our systems in archived form, after it is deleted from primary storage.

PLEASE NOTE THAT REMOVAL OF THE APP FROM YOUR DEVICE DOES NOT CAUSE A DELETION OF THE INFORMATION YOU VOLUNTARILY PROVIDED OR INFORMATION THAT WE COLLECTED IN ACCORDANCE WITH THIS POLICY. YOUR PERSONAL INFORMATION WILL BE DELETED BY US (IN ACCORDANCE WITH OUR DATA RETENTION POLICY) FOLLOWING YOUR REQUEST OR AFTER YOU HAVE BEEN REMOVED FROM THE BUSINESS’ CUSTOMER MEMBERSHIP CLUB AND FROM OTHER BUSINESSES’ CUSTOMER MEMBERSHIP CLUBS WHICH ARE USING OUR CLM SOLUTION AND WHICH YOU HAVE REGISTERED YOURSELF TO.

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Information Security

Security measures are implemented to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures are unable to provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed and you cannot reasonably expect that the App and its related databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse.

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Changes to this Policy

This Policy may be changed from time to time. Substantial changes will take effect 30 days after an initial notification is posted through the App. Other changes will take effect 7 days after their initial posting. However, if the Policy is amended to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required. The most up-to-date Policy is accessible through the App’s settings or information menu.

You agree to be bound by any of the changes made to this Policy. Your continued use of the App after the changed take effect will indicate your acceptance of the amended Policy. If you do not agree with the amended Policy, you must uninstall the App and avoid any further use of it.

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Contact Us

You may send requests, responses, questions and complaints by email.

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Last Updated: January 24, 2016.