Updated: September 2020

We, at Kenshoo Ltd. and its affiliates, put great efforts in making sure that we secure your personally identifiable information and use it properly.

This policy explains our privacy practices for processing our customers’ (“Customer”) and our customers’ end-users’ (“User”) personally identifiable information. Whether you are a User of our cloud-based digital advertising and marketing optimization technology, available on the Kenshoo platform or application and related services, a visitor to our website or if you engage with us through other registration or contact channels (the “Service“), we process personally identifiable information related to you pursuant to the terms of this policy.

The summary of this policy will give you a quick and clear view of our practices. Please take the time to read our full policy.

In Summary

Overview of Our Service – We allow our Customers to manage, optimize and analyze their digital marketing activities. As such, we do not have a direct relationship with Users. Read more.

The Personally Identifiable Information That You Provide Us – We receive and store any information you enter on our website or give us in any other way. If you register with the Service we will need your name, your company name, email address and password, for registration and notice purposes; and we will receive any personally identifiable information that you provide when contacting us. Read more.

The Personally Identifiable Information That We Collect – We automatically log ‘traffic/session’ information including IP addresses and user agent. We collect session durations and additional activity information. Read more.

What Do We Do with Personally Identifiable Information? – We maintain the Service, make it better and continue developing it, and protect us and the Service from misuse and law violations. Read more.

Sharing Personally Identifiable Information with Others – We use service providers to facilitate our Service. We will transfer information when we change our corporate structure, and we will share the information with our affiliate entities. Read more.

Analytics and Marketing Automation – Aggregated data is not identifiable. We use it for legitimate business purposes and for standard analytical and marketing automation tools. Read more.

Information Security – We implement systems, applications and procedures to secure your personally identifiable information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. Read more.

Data retention – We retain data to provide the service and for legitimate and lawful purposes, as further explained in the data retention section of the policy. Read more.

Your Choice – You may opt-out of our mailing lists and terminate your use of the Service. Our Service does not respond to Do Not Track (DNT) signals. Read more.

Accessing Your Personally Identifiable Information – At any time you can request access to your personally identifiable information. Read more.

Specific Provisions for California Residents– If you are a California resident, you are entitled to specific privacy rights. Read more.

Your EU Data Subject Rights – If we process your personal data when you are in the EU, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws. Read more.

Transfer of Data Outside your Territory – We use cloud based services to store and process data in the European Union and in the United States and will store them at additional sites, at our discretion. These service providers provide us adequate security and confidentiality commitments. Read more.

EU-US Privacy Shield – We are self-certified to the EU-US Privacy Shield Framework, in connection with processing personally identifiable information from EU member states. The Federal Trade Commission (FTC) has jurisdiction over our compliance. Read more.

Dispute Resolution – Contact us at: privacy@kenshoo.com or write us for every request and complaint. We will make good-faith efforts to resolve any existing or potential dispute with you. As an EU data subject, you may refer unresolved complaints to our designated recourse mechanism and invoke arbitration in certain cases. Further details are available at: https://www.privacyshield.gov/participant?id=a2zt0000000011jAAA&status=Active.

Changes to this Privacy Policy – We will update our policy from time to time.

Contact Us – Please contact us at: privacy@kenshoo.com for further information.

      • Customer”:
        An entity that has entered into an agreement with Kenshoo and is receiving the Kenshoo Services.
      • Customer Website”:
        A website or other application, operated by a Customer.
      • Engagement”:
        Any interaction of a User (including viewing and/or clicking) with Customer’s advertisement or website.
      • Kenshoo” (or “us”, “we” or “our”):
        Kenshoo Ltd. 6 Ha’barzel St., Tel-Aviv, Israel 6971010 or any of its subsidiaries.
      • Kenshoo Services” (or “Services”):
        Services provided by Kenshoo.
      • Kenshoo Site” (or “Site”):
        www.kenshoo.com or any of its pages.
      • Privacy Policy” or “Policy”:
        Kenshoo’s privacy policy as described herein.
      • User”:
        An individual who visits or otherwise engages a Customer Website.

 

Overview of Our Services

Overview of Our Services

We allow Customers to manage, optimize and analyze their digital marketing activities across multiple advertising channels and devices. As such, we do not have a direct relationship with Users who engage with our Customers or are exposed to Customer’s advertisements that are managed using our Service. We process information related to Users as part of the provision of our Service to our Customers as detailed below

We require our Customers to acknowledge this Privacy Policy to promote transparency of our privacy practices to Users.

Kenshoo requires its Customers to acknowledge this Privacy Policy to promote transparency of our privacy practices to Users.

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The Personally Identifiable Information That You Provide Us

The Personally Identifiable Information That You Provide Us

We receive and store any information you enter when using our Service or give us in any other way.

You provide most of your information through forms you fill out on our website to contact us.

When you contact us, or when we contact you, we will receive and process any personally identifiable information that you provide us.

This information will only be used for the purpose of evaluating, contacting and serving the prospective customers and/or candidates applying for a position. If you are a candidate applying for a position through our Site, please see our Recruitment Privacy Policy.

Note that you are not required by law to provide us with any information about you.

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The Personally Identifiable Information That We Collect

The Personally Identifiable Information That We Collect

We collect information in a number of ways as described below, to provide our Service and for other purposes that we describe in this privacy policy.

  1. Data obtained from engaging Customers’ ads and/or websites:

As part of our Service, we offer our Customers anonymous tracking of Users who engage Customer’s ads and/or website (“Engagement”). Consequently, we collect the following information:

  • The time and date of the Engagement;
  • Details about the device, operation system and browser used by the User;
  • The IP address associated with the User’s specific device;
  • The URL of the landing page of the Customer website;
  • The URL of the referring website;
  • Targeting data disclosed by publishers (e.g. keywords).

In order to obtain this information, we use Tracking Pixels and Cookies.

A Tracking Pixel is a piece of code embedded on a web page of Customer’s website that collects information about Users’ engagement on that web page. The Tracking Pixel can be provided either by the advertising channels, affiliate networks or by us. The Tracking Pixel may include a command to create Cookies. For further information about Cookies please see our Cookies and Tracking Technologies Policy.

A Cookie is a small text file that can be stored on a User’s browser (on any type of device). Our Cookies contains a random unique identifier that enables anonymous tracking activity from a browser that is associated with products and services of a Customer.

  1. Data obtained from transaction consummated between User and Customer at Customer’s physical place of business (“Transaction”).
  • Users’ name, email and phone number provided by the User in a Transaction, and the time and value of such Transaction.
  1. Data obtained from Customers or from third parties:

Subject to Customer’s approval, we will collect information of Customers or of third-party partners, and combine it with our other data in our possession. Such information is un-identifiable, and we do not know, nor will we attempt to know the identity of Users. For example, Customers may generate and send us anonymous Users’ IDs in order to associate cross-device activity of same User.

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What Do We Do with Personally Identifiable Information?

What Do We Do with Personally Identifiable Information?

We use the personally identifiable information we collect and receive to provide the Service, to enable the Service’s tools and features, to study and analyze the functionality of the Service and Customers’ and Users’ activities, to provide support, to measure Service activity, conduct surveys and send questionnaires; provide various reports and enhance our Services to our Customers to maintain the Service, to make it better and to continue developing the Service.

Additionally, we facilitate advertisements based on past interactions of Users with Customer’s advertisements and websites (retargeting services).

We use automated processes, including automated decision making to provide our Service and enhance our customers online marketing capabilities and campaigns.

We process personally identifiable information related to prospective customers who engaged us through our website or to candidates applying for a position on our website. This information will only be used for the purpose of evaluating, contacting and serving the prospective customers and/or job candidates.

We obey the law and expect you to do the same. If necessary, we will use personally identifiable information related to you to enforce our terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service, and to take any action in any legal dispute and proceeding.

We commit to process personally identifiable information solely for the purposes described in this policy.

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Sharing Personally Identifiable Information with Others

Sharing Personally Identifiable Information with Others

We do not sell, rent or lease your personally identifiable information. We will share personally identifiable information related to you with service providers and other third parties, if necessary to fulfill the purposes for collecting the information. Any such third party will commit to protect your privacy as required under the applicable law and this policy.

We will also share your personally identifiable information with our affiliates. These mean companies within the Kenshoo group and include subsidiaries, sister-companies and parent companies, with the express provision that their use of your personally identifiable information will comply with this policy.

We will disclose or use Users’ or our website’s visitors’ data to defend or enforce our legal rights and in accordance with any applicable law. We will disclose personally identifiable information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Additionally, a merger, acquisition or any other structural change will require us to transfer your personally identifiable information to another entity, as part of the structural change, provided that the receiving entity will comply with this policy.

We will be liable for onward transfers to third parties in violation of the Privacy Shield Principles. For further information, please below the EU-US Privacy Shield chapter of this policy.

We will share your personally identifiable information only subject to the terms of this policy, or subject to your prior consent.

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Analytics and Marketing Automation

Analytics and Marketing Automation

We use third parties’ analytics tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content. We also use third party marketing automation tools to help us with our marketing efforts.

We use the standard analytics tools of Google Analytics we will use additional or other analytics tools, from time to time, to learn about how you and other users use the Service, in support of our Service-related activities and operations.

The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: http://www.google.com/analytics/learn/privacy.html.

These service providers use cookies, pixel tags or other technologies to collect and store information. You can prevent analytics and marketing automation services from recognizing you by disabling third party cookies on your web browser, as further detailed in our Cookies and Similar Tracking Technologies Policy.

We use anonymous, statistical or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to you.

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Information Security

Information Security

We and our hosting services implement systems, applications and procedures to secure data we collect and process, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Service will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

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Data Retention

Data Retention

We retain different types of personally identifiable information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law.

We will maintain your contact details, to help us stay in contact with you. At any time before, you can contact our privacy team at: privacy@kenshoo.com and request to delete your contact details. Note that we may keep your details without using them unless necessary, and for the necessary period of time, for legal requirements and proceedings.

We will keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

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Your Choice

Your Choice

At any time, you can unsubscribe from our mailing lists by sending an opt-out request to privacy@kenshoo.com.

At any time, you can stop using our website or terminated your use of our Service. Termination of your Service account is subject to the terms of your subscription agreement with us.

At any time, you can exercise your following opt-out options:

  • object to the disclosure of your personally identifiable information to a third party, other than to third parties who act as our agents to perform tasks on our behalf and under our instructions; or,
  • object to the use of your personally identifiable information for a purpose that is materially different from the purposes for which we originally collected such information, pursuant to this policy, or you subsequently authorized such use.

 

You can exercise your choice by contacting us at: privacy@kenshoo.com.

We request and collect minimal personally identifiable information that we need for the purposes that we describe in this policy. Following the termination or expiration of the Service, we will stop collecting any personally identifiable information from or about you.

However, we will store and continue using or making available your personally identifiable information according with our data retention section in this policy.

Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on a service or through cross-site user tracking. Our Service does not respond to DNT signals.

Cookie opt-out – You may elect to opt-out of enabling Cookies in the browser’s settings tools, usually by choosing between several options offered by the browser. For further information about Cookies please see our Cookies and Tracking Technologies Policy.

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Accessing Your Personally Identifiable Information

Accessing Your Personally Identifiable Information

At any time, you can contact us at: privacy@kenshoo.com and request to access the personally identifiable information that we keep about you. We will ask you to provide us certain credentials to make sure that you are who you claim to be and to the extent required under the applicable law, will make good-faith efforts to locate your personally identifiable information that you request to access.

If you are eligible for the right of access under the applicable law, you can obtain confirmation from us of whether we are processing personally identifiable information about you, and receive a copy of that data, so that you could –

  • verify its accuracy and the lawfulness of its processing;
  • request the correction, amendment or deletion of your personally identifiable information if it is inaccurate or if you believe that the processing of your personally identifiable information is in violation of the applicable law or the Privacy Shield Principles (please see the EU-US Privacy Shield section in this policy for further information).

We will use judgement and due care to redact from the data which we will make available to you, personally identifiable information related to others.

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Specific Provisions for California Residents

Specific Provisions for California Residents

This section applies solely to users of our Service who reside in the State of California.

The personal information that we collect

In the preceding twelve (12) months we have collected the following categories of personal information:

  • Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as names, telephone numbers, business postal addresses, Internet Protocol address, email address and the time and value of a Transaction.
  • Commercial information related to a Transaction.
  • Internet or other similar network activity.
  • Inferences drawn from other personal information.

Our business purposes for collecting your personal information

We collect your personal information for various business purposes, such as to provide you with the Service and make it better, all as described above under the section titled What Do We Do With Personally Identifiable Information.

The categories of sources from which your personal information is collected

We obtain the categories of personal information listed above from various sources, including directly from Users and our website’s visitors, from your Service activities and from third party service providers, as further described above under the section titled The Personally Identifiable Information That We Collect.

The categories of third parties with whom we share your personal information

We may share your personal information with various third parties such as our service providers and our affiliates, as further described above under the section titled Sharing Personally Identifiable Information with Others.

The categories of personal information disclosed to said third parties:

In the preceding twelve (12) months we have disclosed the following categories of personal information for business purposes:

  • Identifiers and Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as names, telephone numbers, business postal addresses, Internet Protocol address, email address and the time and value of a Transaction.
  • Commercial information related to a Transaction.
  • Internet or other similar network activity.
  • Inferences drawn from other personal information.

In the preceding twelve (12) months, we have not sold personal information.

Your Rights as a California Resident

You are entitled to the following specific rights under the California Consumer Privacy Act (‘CCPA’) in relation to your personal information:

Access to Specific Information and Data Portability Rights

You have the right to request that we will disclose certain information to you about our collection and use of your personal information over the past 12 months. After verifying your request, we will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting that personal information;
  • The categories of third parties with whom we share that personal information;
  • The specific pieces of personal information we collected about you;
  • If we disclosed your personal information for a business purpose, we will provide you with a list which will identify the personal information categories that each category of recipient obtained.

Deletion Rights

You have the right to request that we delete your personal information. Upon confirmation of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception under applicable law applies.

Exercising Your Rights

To exercise the access, data portability, and deletion rights described above, please submit your request to us by sending an email to: privacy@kenshoo.com.

Only you or a person authorized to act on your behalf, may make a request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

A request for access can be made by you only twice within a 12-months period.

We cannot respond to your request or provide you with the requested personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use the personal information provided in your request to verify your identity or authority to make the request.

We will do our best to respond to your request within 45 days of its receipt.  If we require more time (up to additional 45 days), we will inform you of the reason and extension period in writing.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures that we provide will only cover the 12-month period preceding receipt of your request.

The response we provide will also explain the reasons for our inability to comply with your request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before processing further your request.

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Your EU Data Subject Rights

Your EU Data Subject Rights

If EU data protection laws apply to the processing of personal data related to you by Kenshoo, then the following terms apply:

Under EU data protection laws, Kenshoo, will be considered a data processer as such term is defined therein, with respect to its Services, except for Kenshoo’s website. As for the Kenshoo’s site, Kenshoo is a data controller, as such term is defined in the EU data protection, and the following will apply only in such case. Where we process personal data related to you as a data controller, the processing is based on the following lawful grounds:

  • All processing of your personal data which are not based on the lawful grounds indicated below, are based on your consent.
  • We process your account and payment details to perform the contract with you.
  • We will process your personal data to comply with a legal obligation and to protect your and others’ vital interests.
  • We will further rely on our legitimate interests, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:
    • Communications with you, including direct marketing where you are our client or a user of our client, or where you make contact with us through our website and other digital assets.
    • Cyber security
    • Support, customer relations, service operations
    • Enhancements and improvements to yours and other users’ experience with our services.
    • Fraud detection and misuse of the Service.

In addition to your rights under other sections in this policy, you have the following rights:

  • AT ANY TIME, CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA. EXERCISING THIS RIGHT WILL NOT AFFECT THE LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.
  • Request to delete or restrict access to your personal data. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
  • If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold your personal data, in accordance with this policy, will act accordingly.
  • You may ask to transfer your personal data in accordance with your right to data portability.
  • You may object to the processing of your personal data for direct marketing purposes. Additional information about this right is available under the Choice section in this policy.
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
  • You have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR.

 

A summary and further details about your rights under EU data protection laws, is available on the EU Commission’s website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will further ask you questions to understand the nature and scope of your request.

If we need to delete your personal data following your request, it will take some time until we completely delete residual copies of your personal data from our active servers and from our backup systems.

If you have any concerns about the way we process your personal data, you are welcome to contact our privacy team at: privacy@kenshoo.com, or write to us to: Kenshoo Ltd., 30 Ha’barzel St., Tel-Aviv, Israel 6971010. We will look into your inquiry and make good-faith efforts to respond promptly.

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Transfer of Data Outside Your Territory

Transfer of Data Outside Your Territory

We store and process information in various sites throughout the globe, including on sites operated and maintained by cloud-based service providers.

From time to time, we will make operational decisions which will have an impact on the sites in which we maintain personally identifiable information. We make sure that our data hosting service providers, provide us with adequate confidentiality and security commitments

If you are a resident in a jurisdiction where transfer of your personally identifiable information to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer. You can contact our privacy team at: privacy@kebshoo.com for further information about data transfer.

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EU-US Privacy Shield

EU-US Privacy Shield

We are self-certified with the US Department of Commerce – EU-US Privacy Shield Framework, in connection with the collection, use, and retention of personal information from EU member states. We are committed to adhere to the Privacy Shield principles, including notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, recourse, enforcement and liability.

For further information about the Privacy Shield program and to view our certification page, please visit: https://www.privacyshield.gov/list. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. The Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield.

We are further committed to refer unresolved Privacy Shield complaints to TRUSTe, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services of TRUSTe are provided at no cost to you.

Kenshoo commits to cooperate with UK’s independent data protection authority (ICO) and comply with the advice given by the ICO about human resources data transferred from the EU of a human resources nature.

Kenshoo commits to cooperate with UK’s independent data protection authority (ICO) and comply with the advice given by the ICO about human resources data transferred from the EU of a human resources nature.

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Dispute Resolution

Dispute Resolution

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this policy, to update the policy when we believe that we need to, and to verify that we display the policy properly and in an accessible manner. If you have any concerns about the way we process personally identifiable information related to you, you are welcome to contact our privacy team at: privacy@kenshoo.com, or write to us. Our address is published on our website at: www.kenshoo.com and, if applicable, is indicated in your subscription agreement with us.

We will look into your query and make good-faith efforts to resolve any existing or potential dispute with you.

In compliance with the EU-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of personally identifiable information related to you. European Union individuals with inquiries or complaints regarding this privacy policy should first contact our privacy team at: privacy@kenshoo.com.

Additionally, if you are an EU data subject, you can invoke binding arbitration in certain cases, as Annex I of the EU-U.S. Privacy Shield Agreement describes. For further information, please visit the Privacy Shield website at: www.privacyshield.gov, or contact our privacy team.

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Changes to this Privacy Policy

Changes to this Privacy Policy

From time to time, we will update this policy. If the updates have minor if any consequences, they will take effect 7 days after posted on our Service and/or published the revised policy in the website. Substantial changes will be effective 30 days after the publication of the revised policy.

Until the new policy takes effect, if it materially reduces the protection of your privacy right under the then-existing policy you can choose not to accept it and terminate your use of the Service. Continuing to use the Service after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.

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Contact Us:

Please contact our Privacy Compliance at: privacy@kenshoo.com for further information.