Privacy Policy

Effective Date: May 22, 2018

This Privacy Policy covers the information practices of any website that links to this Privacy Policy (severally and jointly, the “Site”) and is operated by Raftika Ltd. (“Raftika ”, “we”, “us” or “ours”)or its affiliated companies, and the advertising services (the “Services”) that Raftika  provides to its supply and demand partners.

Raftika  believes strongly in protecting the privacy of information entrusted to us. We acknowledge that you may have privacy and security concerns with respect to the information we collect, use, and disclose to third parties for the purpose of allowing us to offer and provide our products and services, so we have provided this Privacy Policy to explain, in as clear and plain language as possible, how we collect and use information. You will also find an explanation of certain rights you have (see Section 6 (Your Rights)) in respect of your Personal Information.

In this Privacy Policy, Personal Information is any combination of information, in the possession of or likely to come into the possession of Raftika , that can be used to identify, contact, or locate a discrete individual (“Personal Information”).  Personal Information includes any expression of opinion about an individual. Information that does not identify a discrete individual (such as aggregated statistical information) is not Personal Information.

Please read this Privacy Policy carefully, before using the Site or the Services, so you can fully understand our practices in relation to Personal Information, before we begin processing your information.

This Privacy Policy explains:

1. WHAT INFORMATION WE COLLECT AND HOW WE USE IT.

2. LIMITING COLLECTION.

3. DISCLOSURE OF INFORMATION TO OTHERS.

4. TRANSFERS TO THIRD COUNTRIES

5. CONSENT

6. YOUR RIGHTS.

7. HOW WE PROTECT YOUR INFORMATION

8. DIRECT MARKETING.

9. CALIFORNIA’S “SHINE THE LIGHT” LAW.

10. DO NOT TRACK.

11. EXTERNAL LINKS.

12. HOW TO CONTACT US.

13. CHANGES TO THIS PRIVACY POLICY.

The information gathered by Raftika  from the Site is either information voluntarily supplied by Site users or tracking information gathered as users navigate through the Site. In these instances, Raftika  is considered a data controller of this information. In addition, when you use the Services as a demand partner or supply partner, Raftika  collects Personal Information about your end users in order to provide you with the Services. Please note that you are not required by law to provide us with any such Personal Information. In collecting this Personal Information and providing you with the service, Raftika  acts as a processor of this information on your behalf.

1. WHAT INFORMATION WE COLLECT AND HOW WE USE IT.

(I) Information voluntarily provided by you on the Site.

When using the Site, you may choose to provide us with information to help us serve your needs.  The Personal Information that we collect will depend on how you use the Site. For the purposes listed below, Raftika  acts as a data controller and processes the information on the basis of performance of a contract with you.

  • When you request information about our Services, you must submit your name and e-mail address. In addition, you may insert the reason for your communication. We will use this Personal Information to:
    • Determine whether you are an existing client of Raftika ;
    • Send you the material you have requested;
    • Assist you in the completion of your application;
    • Assess your eligibility for any requested service
    • Responding to your inquiries about accounts and other services; and
    • Making proposals for future service needs.

We will retain your Personal Information for the amount of time necessary in order to process your inquiries and respond to your requests. If we have not received a communication from you within 9 months, or you have asked to delete your Personal Information, we shall immediately delete records of your Personal Information.

  • Following an inquiry into receiving the Services from us and when you register to proceed with the Services, we ask you for your name, your position and the organization you work for, e-mail address, country, postcode, telephone number, billing address or payment details.
    We use this information to:

    • Provide and maintain the Service to you, including performing payment processing operations (through third party service providers);
    • Renewal of the Service;
    • Establish and maintain communications with you and other users;
    • Making proposals for future service and product needs; and
    • Allowing our affiliated companies to notify you of certain products or services they offer.

To the extent that you are using the Services, we will store your information for the period in which you have an account with us to provide you with the Services. After you close your account, we will continue to retain and use your Personal Information only to the extent required by applicable law or auditing requirements.

(II) Tracking Information when users navigate the Site.

As you navigate this Site, we also use commonly-used information-gathering tools, such as cookies and web beacons to operate the Site and provide you with certain features and functionalities. These tools collect standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address and the actions you take on the Site (such as the web pages viewed and the links clicked). The legal basis for processing this information is for the performance of a contract with you and our legitimate interest in being able to provide and improve the functionalities of the Site offered to you. If you are located in the European Union, we also rely on your consent to use cookies.

What are these tools and how do we use them?

  • Cookies

Like many companies, we may use cookies on the Site. Cookies are pieces of information shared between your web browser and the Site.  Cookies enable us to offer a faster and easier user experience. A cookie cannot read data off your computer’s hard drive.

Different kinds of cookies have different functions:

  • Session cookie: a session cookie is stored on your computer during your web session and is automatically deleted when your browser is closed.  A session cookie usually stores an anonymous session ID allowing you to browse a website without having to log in to each page. Session cookies do not collect any information from your computer.
  • Persistent cookie: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. A persistent cookie can be read by the website that created it when you visit that website again.
  • First-party cookie: a first-party cookie retains your preferences for a particular website for the entity that owns that website. Raftika ’s first-party cookies are stored and sent between Raftika ’s servers and your computer’s hard drive but are not used for anything other than for personalization as set by you. A first-party cookie may be either a session cookie or a persistent cookie.
  • Third-party cookie: a third-party cookie retains information about your interaction with a particular website for an entity that does not own that website, i.e., a third party. Third-party cookies are stored and sent between the third-party’s server and your computer’s hard drive. Third-party cookies are usually persistent cookies.

The Site does use Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses cookies to help Raftika  analyze how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) is transmitted to and stored by Google on servers in the United States.  Google uses this information for the purpose of evaluating your Site use, compiling reports on Site activity, and providing other services relating to Site activity and internet usage for Raftika  and its affiliates.  Google may also transfer this information to third parties when required by law or when third parties process information on Google’s behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note, however, that if you do this you may not be able to use the full functionality of this Site.  By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

For information on all of these categories of cookies and for more information generally on cookies, please refer to aboutcookies.org.

We use cookies for the following purposes:

Where strictly necessary

We use cookies to enable you to move around this Site and use its features, such as accessing secure areas of this Site, and to improve your user experience on the Site. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

Performance and Analytics

We use cookies to collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages.  They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that the Site works.  We use this to improve how the Site works. We also compile statistics for analysis of the Site and our business.

Functionality

These cookies allow the Site to remember choices you make (such as your user name, language or the region you are in (learnt from your IP Address)) and provide enhanced features. For instance, a Site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access the Site. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on an article.

Please consult your web browser’s ‘Help’ documentation or visit www.aboutcookies.org for more information about how to turn cookies on and off for your browser.

  • Web Beacons

The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from Raftika . Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications.  We may use information from web beacons in combination with other anonymous data we have about our clients to provide you with information about Raftika  and our services.  We will conduct this review on an anonymous basis.

We will retain the tracking information described above for 9 months.

(III) Information when you use the Services.

As stated above, when you use the Services as a demand partner or supply partner, Raftika  collects Personal Information about your end users in order to provide you with the services. The following end user Personal Information that we collect is:

  • Mobile Advertising ID for Services performed via a mobile device;
  • IP address.

We may also collect other non-Personal Information in providing the Services including:

  • Device make, model and operating system;
  • Device properties related to screen size & orientation, audio volume and battery;
  • Carrier;
  • Operating system;
  • Name and properties of mobile application through which a consumer interacts with the Services;
  • Country, time zone and locale settings (country and preferred language);
  • Network connection type and speed; and
  • Activity of a user on an application following installation; and
  • Internet browser user-agent used to access the Services.

In collecting this information and providing you with the Services, Raftika  acts a processor on your behalf. Please note that you must ensure that our processing activities described below are consistent with the lawful basis of your own processing of Personal Information.

  • Services to Supply Partners: Raftika  use this information to find and serve the optimal advertisement for the end user of your mobile website or application (the “Property”). In addition, Raftika  passes this information on to the Advertiser’s tracking vendor for tracking purposes so that an install event can be detected (which then triggers a payment to you, ie. the Supply Partner). Please note that Raftika  only collects information from the Property to the extent that you have instructed and allowed Raftika  to collect, in writing, prior to such collection, and subject to the permissions you have activated inside the Property.
  • Services to Demand Partners: Raftika  uses this information to facilitate and optimize campaigns for advertisers across its network. It only uses the Personal Information provided by a demand partner to optimize campaigns for this demand partner – Raftika  does not cross-use Personal Information received from one advertiser to optimize the campaigns of another advertiser. Raftika  will receive data from your tracking vendor on whether an event which triggers payment to Raftika  or measures quality of the installs provided by Raftika  has occurred on a Property. This is so we can serve your advertisement on the Properties of our supply partners and pay them for certain events agreed between us (eg. installs, certain interactions on a Property etc.).
  • Services to all our customers: We also use the information to detect and prevent fraudulent actions of end users. For example, we will detect multiple requests from a certain piece of information (eg. IP address) that could not reasonably be performed by a human being in such time or volume.

We will retain the Personal Information described above for the life of an active campaign and for six (6) months thereafter, or until you instruct us otherwise to delete such information, noting that we will continue to retain and use your Personal Information for longer periods only to the extent required by applicable law or auditing requirements.

(IV) Third Party Information you provide

When you supply us with information containing third-party Personal Information (names, addresses, or other information relating to living individuals) excluding Personal Information of end users provided in connection with your use of the Services, we will hold and use that Personal Information to perform services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason for obtaining the Personal Information, the fact that it may be disclosed to third parties such as Raftika , and have consented to such disclosure and use.

We will retain the Personal Information described above for the period in which we have an active business relationship with you or until you ask us to delete such data, noting that we may receive consent directly from the data subject of such Personal information directly, in which case the retention period and use shall be governed by our relationship with such data subject.

(V) Legal Purposes for collecting, using and disclosing Personal Information.

In addition to the above, we use Personal Information for meeting legal, security and regulatory requirements, to recover and make payments from you (including in cases of payment disputes), and to protect against suspicious or other illegal activities.

We will retain this Personal Information for the amount of time as required by law to fulfill the foregoing purposes. This may include to ensure we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

2. LIMITING COLLECTION.

Raftika  will collect, use, or disclose Personal Information that is necessary for the purposes described above or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose and will only be used and processed subject to your consent (where appropriate).

3. DISCLOSURE OF INFORMATION TO OTHERS.

We do not disclose any Personal Information about you to third parties except as stated in this Privacy Policy, as permitted by law, or authorized by you. Third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure in compliance with all applicable laws.

Third parties to whom we disclose Personal Information include:

  • Service providers who assist in providing the Site and the Service including:
    • Payment processing service providers are used to process transactions for the Services. They will receive your banking and payment details;
    • Tracking vendors which assist in providing the Services to Demand and Supply Partners; and
    • Communication and marketing platforms are used to communicate with you and notify you of our products and services;
    • Providers of core business infrastructure such as hosting platforms and back-up providers. They are used to store all Personal Information collected by Raftika .
  • In the normal course of providing Services for our clients, we may share Personal Information within Raftika  and its affiliates for system administration, storing or processing such information on our behalf to provide the Site and the Services, and for crime, fraud prevention or detection and compliance with applicable law.
  • As we continue to develop our business, we might sell or buy assets. In such transactions, user information (including Personal Information) generally is one of the transferred business assets. Also, if either Raftika  itself or substantially all of Raftika  assets were acquired, your Personal Information may be one of the transferred assets.   Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances
  • Raftika  preserves the right to disclose without your prior permission any Personal Information about you or your use of the Site or the Services if Raftika  has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of Raftika , employees, other users of the Site, the Services or the public; (b) enforce the terms and conditions that apply to use of the Site and the Services; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental requests.

4. TRANSFERS TO THIRD COUNTRIES.

Raftika  is located and maintains servers and other storage facilities in the United States (and in Japan for support of the Services provided in Japan). As a consequence of your use of the Site or the Services, Personal Information may be used or stored in the United States. By using the Site or the Services, you hereby affirmatively consent to the processing of Personal Information in a country which may not have the same level of privacy protection as your country of residence or of your end users. Should you withdraw this consent, you agree that you will not use or visit the Site or use the Services subsequent to your withdrawal of such consent. The way to withdraw your consent is described below under the heading “Consent”.

Raftika  will take appropriate steps to ensure that transfers of Personal Information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end:

  • where we transfer your Personal Information outside of Raftika , for example to the service providers listed above, we obtain contractual commitments from them to protect your Personal Information. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Information transferred from within the EU to the United States, an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission); or
  • where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

Subject to applicable laws, you have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your Personal Information when this is transferred as mentioned above. See “Your Rights” section below for more details.

5. CONSENT.

Your knowledge of and consent to Raftika ’s collection, use and disclosure of your Personal Information is important. We rely on the following actions by you as indications of your consent to our existing Personal Information practices:

  • Your voluntary provision of Personal Information to us directly;
  • Your express consent or acknowledgement contained within a written, verbal or electronic application or claims process; and
  • Your verbal consent solicited by Raftika  (or our agent) for a specified purpose.

Where Raftika  relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.

Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. Raftika  will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for Raftika  to collect, use or disclose your Personal Information could mean that we cannot provide the requested services or information for you.

If you wish to withdraw your consent (which may limit or terminate the products and services that Raftika  provides to you), simply tell us that you would like to withdraw your consent through writing or emailing us at:

Raftika  Ltd.

Attn: Customer Care

38 Head Haam Tel Aviv, Israel 

[email protected]

We ask that you be specific as to whether you would like to withdraw your consent to the processing of your Personal Information or just some.

However, please note that there are a number of instances where Raftika  does not require your consent to engage in the processing or disclosure of Personal Information. Raftika  may not require your consent for the processing or transfer of Personal Information for the those purposes which have a statutory basis, such as:

  • The transfer or processing is necessary for the performance of a contract between you and Raftika  (or one of its affiliates);
  • The transfer or processing is necessary for the performance of a contract, concluded in your interest, between Raftika  (or one of its affiliates) and a third party;
  • The transfer or processing is necessary, or legally required, on important public interest grounds, for the establishment, exercise, or defense of legal claims, or to protect your vital interests; or
  • The transfer or processing is required by applicable law.

6. YOUR RIGHTS.

Raftika  does not provide online access to its customers to view or amend Personal Information in its database, however, you have the right to ask Raftika  to amend any Personal Information it holds about you if it is inaccurate or misleading. We also note that our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request so we encourage you keep us informed of changes to your Personal Information. To update your details, please contact us by email at [email protected]

 or at the following address:

Raftika  Ltd.

Attn: Customer Care

38 Head Haam Tel Aviv, Israel

The following rights (which may be subject to certain exemptions or derogations), shall apply in addition to the above to EU users of the Site or the Services:

  • You have a right to access information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
  • If you no longer want us to use your Personal Information, you can request that we erase your Personal Information. Please note that if you request the erasure of your Personal Information, we will not be able to process your transactions or provide you with the Services. We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend use for fraud or safety reasons, we may retain certain information about that user from processing another transaction through the Site and the Service. We may also retain and use your Personal Information to the extent necessary to comply with our legal obligations, including for tax, legal reporting and auditing obligations. Also, because we maintain the Site and the Service to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.
  • You have a right to restrict the processing of your Personal Information, for example in case when we no longer need your Personal Information for the initial purposes for which they were collected, but they are required by you for the establishment, exercise or defense of legal claims.
  • Where you have provided your consent to the processing of your Personal Information by Raftika  you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
  • You have a right to object to our use of your Personal Information for direct marketing purposes. See the “Direct Marketing” section and the explanation of “Cookies” above for how to unsubscribe, manage your marketing preferences and opt out of cookies.
  • You have a right to obtain a portable copy of Personal Information which is processed on the basis of your consent, or which is necessary for the performance of a contract between us. You have a right to have such portable copy of Personal Information transferred to another data controller in a structured, commonly used and machine-readable format.
  • You also have a right to request details of the basis on which your Personal Information is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
  • You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.

In the event that your request, for example, would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

7. HOW WE PROTECT YOUR INFORMATION.

We have implemented and will maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. Note that, although we take measures to secure the information we collect and reduce the risk of unwanted disclosure, we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer or device you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

8. DIRECT MARKETING.

As stated above, we may use your Personal Information to let you know about our products and services that we believe will be of interest to you. We may contact you by email, or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you. To protect privacy rights and to ensure you have control over how we manage marketing with you:

  • we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
  • you can ask us to stop direct marketing at any time – you can ask us to stop sending email marketing, by following the ‘unsubscribe’ link you will find on all the email marketing messages we send you. Alternatively you can contact us at [email protected] Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email); and
  • you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser.

9. CALIFORNIA’S “SHINE THE LIGHT” LAW.

California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what Personal Information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties. Raftika  does not share any Personal Information collected from the Site with third parties for their direct marketing purposes.

10. DO NOT TRACK.

Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature”); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Raftika  does not currently respond or recognize DNT Feature signals.

11. EXTERNAL LINKS.

The Site or the Service may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any Personal Information you provide is governed by the privacy policy of the operator of the website you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these websites via a link from the website’s homepage, you should contact the website directly for more information.

12. HOW TO CONTACT US.

If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy, or if you wish to exercise your rights, please contact us at [email protected] 

You can also contact us at the following address:

Raftika Ltd 

Attn: Customer Care

38 Head Haam Tel Aviv, Israel

We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honor your wishes to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

13. CHANGES TO THIS PRIVACY POLICY.

Raftika  will provide you with 30 days advance notice of any material change to your rights under this Privacy Policy. Raftika  will post a notice of the change on the Site in a clear and conspicuous manner for the 30-day notice period. Raftika  will also communicate the change via email or postal mail. Please note that your continued use of the Site after this 30-day period or after the Effective Date above indicates your agreement to the Privacy Policy as amended.

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