PRIVACY POLICY

Last Updated: September, 2020

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Introduction

We at Playform Ltd. (“us”, “we”, "Playform" or the “Company”) respect your privacy and are committed to protect the privacy of our users (“User” or “you”).

This Privacy Policy outlines our practices with respect to receiving, collecting, using and disclosing your information through our website(s), and our application (“App”), (collectively, the “Services”). In order for us to provide you with our Services we are required to collect and process certain Personal Data (defined below) about you and your activity.

The Privacy Policy is a part of our Terms of Use and is incorporated therein by references.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to this Privacy Policy.

 

What type of data we collect?

Personal Data

"Personal Data" is data that identifies an individual or that may, with reasonable effort, identify an individual.

In the course of using the Service, we may ask you to provide us with certain Personal Data to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Service, and as otherwise indicated in this Privacy Policy. We collect the following Personal Data about you:

From players:

• Registration information – when you sign up to use our Services, we will collect certain information that can be used to identify you and to provide you with the Services, such as your name, your phone number, your date of birth, your gender, your dominant foot and your height.  

• When using our Services – when you use the Services, we will collect the videos, pictures and content you upload to the App.

• Payment information: in order for you to enjoy all of the functions which we offer, we collect payment information from you, including your credit card number and bank account details. Please note that your billing information, to the extent provided by you, is forwarded directly to a third party billing or clearing company engaged by us and is not kept by us.

• Voluntary information: you may choose to provide us Personal Data voluntarily, such as when you contact us (via a contact form on our Services, e-mail or any other channel, including any support services), we may also collect additional profile information.

• Device information: we collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.

• Information from third parties – our Services allow registration using social media accounts such as Facebook. If you choose to connect your Playform account with your social media account, we will receive information from your social media account such as your profile name, profile picture and additional information depending on such social media platform and your privacy settings on it.

From coaches

• Registration information – when you sign up to our Services, we will collect certain information that can be used to identify you and to allow you to use the Services, such as your name, your phone number and your email address.

• When using our Services – when you use the Services, we will collect content that you upload to the App and/or send to players.

• Voluntary information: you may choose to provide us Personal Data voluntarily, such as when you contact us (via a contact form on our Services, e-mail or any other channel, including any support services), we may also collect additional profile information.

• Device information: we collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.

• Information from third parties – our Services allow registration using social media accounts such as Facebook. If you choose to connect your Playform account with your social media account, we will receive information from your social media account such as your profile name, profile picture and additional information depending on such social media platform and your privacy settings on it.

 

Non-Personal Data

Non-Personal Data is non-identifiable information that, when taken alone, cannot be used to identify you. As such, we are not aware of the identity of the User from which the Non-Personal Data was collected.

We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. We also collect aggregate user data regarding your use and activity on our Services. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose.

For the avoidance of doubt, if we combine Personal Data with Non-Personal Data (e.g. analytics data), the combined information will be treated as Personal Data as long as it remains combined.

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Tracking Technologies

When you visit or access our Services we use (and authorize 3rd parties to use) pixels, cookies, events, and other technologies (collectively, "Tracking Technologies"). Those allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics and customize your experience. We store Tracking Technologies when you visit or access our Services. These are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners, and advertisers) – these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit to our Services or for repeat visits.

We use a tool called “Google Analytics” to collect information about the use of our Service. Google Analytics collects information such as how often users visit our site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve our Services. Google Analytics collects only the IP address assigned to you on the date you visit our site and plants a cookie on your web browser to identify you as a unique User the next time you visit. The cookie cannot be used by anyone but Google and we do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this site is detailed on the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser as described below.

When sharing your videos outside of the Playform app on 3rd parties apps integrated within the Playform app like TikTok, you agree to comply with their terms of service https://www.tiktok.com/legal/terms-of-use?lang=en Privacy Policy https://www.tiktok.com/legal/privacy-policy?lang=en and community guidelines https://www.tiktok.com/community-guidelines?lang=en.

How to Manage Your Tracking Technologies Settings

There are various ways in which you can manage and control your Tracking Technologies settings. Please remember that, by deleting or blocking Tracking Technologies, some of the features of the Services may not work properly or as effectively.

• Below are some links to some commonly used web browsers. Information about cookies is usually found in the "Help" section of the web browser.

  • Google Chrome

  • Internet Explorer

  • Mozilla Firefox

  • Safari (Desktop)

  • Safari (Mobile)

  • Android Browser

  • Opera

  • Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.

• Mobile Devices - You can-opt out of certain types of interest-based advertising (or “cross-app” advertising), by accessing the “settings” on your device:

  • If you're using an Apple device you can configure your device to limit ad tracking to by clicking on "settings" > "privacy" > "advertising" and toggling "limit ad tracking" to ‘on.’

  • If you're using an Android device you can opt-out of most app-based tracking for advertising by opening the "Google Settings" app on your device, selecting "Ads", and then selecting the option to opt-out of interest-based ads.

Please note that the above information may change when manufacturers update their systems. Also note, that your device may use another platform, not described above. In that case, please consult the manufacturer's documentation for further instructions.

• You can also turn off certain third party targeting and advertising cookies by visiting the following link: Network Advertising Initiative and http://optout.aboutads.info/#!/.

 

Our Policy Toward Children

We understand the importance of protecting children’s privacy, especially in an online environment. We do not knowingly collect or solicit personal information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”).  By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected Personal Data from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.

 

Grounds for Data Collection

Our legal basis for collecting and using your Personal Data will depends on the Personal Data collected and the specific context in which we collect it. We normally collect Personal Data from you only where: (a) we have your consent to do so, (b) where we need your Personal Data to perform a contract with you (e.g. to deliver the Services you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such information under applicable laws.

In some cases, we may need the Personal Data to protect your vital interests or those of another person.

Where we rely on your consent to process your Personal Data, you have the right to withdraw or decline consent at any time.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us through the contact details available below.

 

How Do We Use the Data We Collect?

In addition to the purposes listed herein, the Personal Data we collect is used for the following purposes:

• Provision of the Service - we will use your Personal Data for the provision and improvement of our Services, including for support and to respond to your queries.

• Service communications - we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services, send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages.

• Marketing purposes - we may use your Personal Data to send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners. See more under "Marketing";

• Analytics, surveys and research - from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Service and think of new and exciting features for our Users.

• Protecting our interests - we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of Playform, its Users and/or partners.

• Enforcing of policies - we may use your Personal Data in order to enforce our policies, including but not limited to our client agreement.

• Compliance with legal and regulatory requirements - we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

• Where we obtain your consent: we may also process your Personal Data for other purposes for which we obtain your consent.

 

With Whom Do We Share Your Personal Data?

• Users of the Application – in order to provide our Services, your Personal Data may be shared with other Users, as follows:

  • As a player:

    • You may choose to participate in competitions through the App, in this case some of your Personal Data, such as your name, age, photos, videos and score will be visible to other players.

    • You can choose to share certain information with your professional coach for evaluating your performance and for building personalized trainings for you, in such case the coach will have access to some of your Personal Data, as necessary, such as your full name, photos and videos and additional information regarding your performance.   

  • As a coach:

    • Certain Personal Data about you, including your full name will be visible to the players that you train.

• Service providers - we work with other companies who help us run our business (“Service Providers”). These companies provide services to help us store information (such as cloud storage companies), deliver customer support, monitor and analyze the performance of our Services. These Service Providers may only process Personal Data pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations.

Specifically, we do not permit our Service Providers to use any Personal Data we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.

• Internal concerned parties - we share your information with companies in our group, as well as our employees, in order to provide you with our Services.

• Business partners - we share your information with business partners, such as storage and analytics providers who help us provide you with our Service. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose.

• Compliance with laws and law enforcement entities - we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

• Merger and acquisitions – we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your Personal Data in accordance with the terms of this Privacy Policy.

• As you may otherwise consent from time to time.

 

Transfer of data outside the EEA (for EU data subjects)

Since we operate globally, it may be necessary to transfer data, including Personal Data, to countries outside the EEA. In these instances, we will transfer your Personal Data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

 

How we protect your information

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and is not publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services, and you do so at your own risk.

 

Retention

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing User's Personal Data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

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Marketing

We may use your Personal Data, such as your full name, email address, etc., ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our Websites.

At any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to the details listed below.

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you Service-related updates and notifications.

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User Rights

The laws of some jurisdictions may provide various rights in connection with our processing of certain Information. Such rights may include:

1. The right to receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.

2. The right to receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.

3. The right to request rectification of your Personal Data that is in our control.

4. The right to request erasure of your Personal Data.

5. The right to object to the processing of Personal Data by us.

6. The right to request to restrict processing of your Personal Data by us.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

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Additional Information for California Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ.§1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, "CCPA"). It applies to the handling of Personal Data of our Users who are residents of California (“consumers” or “you”).

 

Collecting Personal Information

In the preceding twelve (12) months, we have collected the following categories of information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”):

Category of Personal Information Collected

Personal Information Collected

Categories of  Sources of Personal Information

Business Purpose for Collection

A.    Identifiers

Name, email address, IP address, username

• Directly from consumers.

• Directly or indirectly from activity on our Services by cookies or other tracking technologies.

• From third parties that interact with us, including social networks, advertising networks and other publicly available sources.

• Operate our Services

• Product development and improvement

• Customer service

• Detecting and protecting against security events

• Internal analytics and reporting

• Internal research

• Maintaining and enhancing service, debugging

• Auditing consumer interaction & transactions

• Advertising and direct marketing

• Detecting/Protecting against security events, preventing fraud and abuse of our policies

• Compliance purposes and meeting legal and regulatory requirements

B.    Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

Name, telephone number, credit card number

C.    Internet or Other Electronic Network Activity Information

Interaction with our Services

• Marketing and advertising providers.

• Data analytics providers.

• Directly from consumer’s device by using cookies or other tracking technologies.

D.   Geolocation Data

Country, State

Directly from consumer’s device by using IP address

E.  Inferences drawn from any of the personal information listed above to create a profile or summary

 

An individual’s preferences and characteristics

• Advertising networks

• Social networks

• Directly from consumer’s device by using IP address, or as directly submitted by the consumer, or as made available on publicly available sources or social media pages.

F.    Commercial Information

Transaction information, purchase history

Internal record of transactions.

G. Audio Visual Information

Photographs, Videos

Directly from you

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Sharing Personal Information

In the preceding twelve (12) months, we have disclosed personal information (as mentioned above) to, or allowed access to personal information by, the following categories of recipients:

• Data analytics vendors

• Quality assurance vendors

• Cloud storage Providers

• Payment and auditing processors

• Service providers

• Advertising networks and marketing affiliates

 

User Rights under the CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Personal Information

You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable.

 

Deletion Requests

You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.

 

Right to Opt-Out of the Sale of Personal Information

We do not "sell" personal information about our Users as most people would typically understand this term. However, we do allow certain third-party partners to collect pseudonymized information about consumers through our Services for purposes of serving ads and related marketing materials that are relevant (including related activities such as campaign measurement and analytics, fraud detection and reporting). In this context, we "sell" resettable advertising identifiers and IP addresses with our advertising partners. These allows developers and marketers to track activity for advertising purposes and are used to enhance the personalization of ads.

You may opt out from the "sale" of your personal information by: (a) using our Opt-Out mechanism available in the app settings or (b) resetting these identifiers from within your device or limit ad tracking for your device as mentioned in the "Tracking Technologies" section of this policy. You may also contact us, by using the contact details provided below.

 

Exercising Your Rights

You can exercise your rights (such as access and deletion) via our in-app settings.

In addition, to request access to your Personal Information or request deletion of your Personal Information, you can also submit a verifiable consumer request to the contact information below.

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:

• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

• Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

• We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

You may only request a copy of your data twice within a 12-month period.

If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at contact information below.

 

Response Timing and Format

Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.

Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.

 

Designating Agents

You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and

• You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

 

Non-Discrimination

Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

How to Contact Us?

If you wish to exercise any of the aforementioned rights, or receive more information, please contact: info@playform.app

 

Updates to This Policy

This Privacy Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our website (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. In the event of material changes, we will provide you with a notice. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.

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