Privacy Policy

INTRODUCTION

Gurutraff Inc. has developed this Privacy Policy (“Policy”) to demonstrate our commitment to protecting our users’ privacy. The terms “Gurutraff,” “we,” “us”, and “our” include Gurutraff Inc. and any affiliates and subsidiaries. The terms “you” and “your” refer to any individuals and entities which use our Online Services or visit our website and our employees. This Policy describes our online and offline information practices, the kinds of information we may collect, how we intend to use that information, with whom your information may be shared, and how you can opt-out of such uses or correct or change such information. By using our Online Services or our website, you agree to the practices described in this Policy. This Policy is an integral part of and is incorporated by reference into our Terms and Conditions (the “Terms”). Any capitalized terms used but not defined in this Policy will have the meaning defined in the Terms. We collect information under the direction of our Publishers, and have no direct relationship with the individuals (“End Users“) whose information we process. We respect the right to privacy of Publishers and End Users. Your ability to make informed choices about the use of your information is important to us, so please read this Privacy Policy carefully to learn about your choices.

PERSONAL INFORMATION

In the process of running our business, Gurutraff gathers personal information. In defining the personal data collected, this actually differs and depends on the legislation (laws) of the location you are at that point in time. The various types of personal data collected by the company will be explained below; attempts will be made to give a clear definition while explaining how we make use of each type of collected data throughout this policy. Personal data has a broad definition, for instance, according to the European Union (EU); it is described to include both PII and Pseudonymous Identifiers as defined below.

PSEUDONYMOUS IDENTIFIERS

Gurutraff gathers what is known as pseudonymous identifiers. Pseudonymous means an identity as a natural person is not known to us, although it assists us in collecting and making use of other personal data to better understand the preferences and interests. These will be explained further in the “Other Personal Data” section which is below. Pseudonymous identifiers will include IP address, Google Advertising ID, Apple identifier for Advertisers.

PERSONALLY IDENTIFIABLE INFORMATION (PII)

PII will be gathered by Gurutraff when you decide to give it to us. PII is any information that Identifies or specifically locates a specific individual or entity. We obtain and store any PII that you provide us with. The retrieved PII types will include your name, postal address, phone number, email address and other PII that you choose to provide on a particular type of information collection. For example, you may choose to send PII about yourself in an email, fill out an online form on the websites, find out more information about a job or apply for jobs, or sign up for our service or e-newsletter. You can also send us PII to create an account in Gurutraff. Gurutraff will use this data in a reasonable manner for our business purposes, we will also contact you if there is a need for you to respond to inquiries made by you in order to keep your account with us or offer the service you requested for. Once your details have been received, they will be stored by Gurutraff for a necessary period of time in order to provide continuous services and equally, for a reasonable length of time for record-keeping purposes.

OTHER PERSONAL DATA

Gurutraff equally gathers personal information from mediums such as our websites, the information could be internet browsing and usage habits, Internet Service Provider, visited Web pages, types of browser used, domain name of our visited Websites, time-stamps of your visits to these websites, computer’s operating system and referring URL. Third-party analytics providers might be used by us to assist in both the managing and gathering of data. We gather data about your apps that display ads viewed, ads, the time/date of these events, mobile service provider, interactions and transactions within ads or apps, and mobile device type and characteristics; all these are collected using our service and platform. This collected data allows us to manage and improve the user experience on our Websites or with our advertising Service.

NOT PERSONAL DATA

Gurutraff will not collect sensitive personal data that will expose philosophical or religious beliefs, ethnic or racial origin, trade union membership, or political opinions.

LOCATION DATA

In some situations, an application running on your mobile phone may allow you to give out permission regarding the sharing of information. Information such as latitude and longitude can be sent to us after you grant permission, we may equally process and store these for ads based on location.

HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect for the following purposes:

  • - Serving ads and promoting apps – allow our Publishers to promote advertising, apps and content in their Online Services Apps, and to allow Advertisers to bid on Publishers’ inventory.
  • - Serve interest-based advertising and personalized content – enable our partners to infer interests and serve ads and personalized content to users based on their behavior, app activity and inferred interests. We will not serve interest-based ads or personalized content based on information that we consider sensitive, such as race, religion or health.
  • - Ad reporting and conversions – measure ad performance, report to Advertisers when and how End Users have viewed or clicked on their ads, or visited their website, and to report to Publishers when and how ads were shown on their properties and were clicked on.
  • - Fraud detection and prevention – identify invalid or incentivized clicks (or ad queries) and protect Gurutraff and our partners from fraudulent behavior.
  • - Enforce our policies, resolve disputes and communicate with you.
  • - Providing and improving our Online Services – audit, research and analyze information in order to maintain, protect, and improve our Online Services and develop new services, and to ensure that our technologies function properly.

INFORMATION SHARING

We share information about you with:

  • - A Publisher whose app you have accessed to – we share information about how you have interacted with that Publisher’s app and its ads and personalized content.
  • - An Advertiser whose site or app you have visited – we share information about how you have interacted with that Advertiser’s site, app or its ads.
  • - With our service providers – we contract with companies who help with parts of our business operations (for example, storage of information). We require that our service providers only use your information in connection with the services they perform for us.
  • - With our subsidiaries and related companies.
  • - In connection with legal proceedings – when we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of Gurutraff, our Partners or any other third party.
  • - In connection with a sale of our business – if a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale.
  • - In addition, we may disclose aggregated, anonymized information with other third parties. However, this information cannot be used to identify you.ns;

HOW WE COLLECT INFORMATION

SDK – the SDK is a bit of computer code that app developers (such as our Publishers) can include in their apps to enable ads and personalized content to be shown, data to be collected, and related services to be implemented.

On our Websites we may use "cookies" to consequently gather data about visitors to the Websites. For more data about the cookies we use visit our cookie declaration page. We also cooperate with Google Analytics to learn how you use our Website. To opt-out of Google Analytics, you can visit this link and follow to the description.

END USER CHOICE AND OPT OUT

Ads delivered through Gurutraff's SDK will allow End Users to out-put with a mechanism that permits End Users to set their preferences.
End Users in the European Economic Area can withdraw their consent given to Gurutraff to collect and process data to optimize interest-based ads, by writing to legal@gurutraff.com indicating on it their Google Advertising ID (android) or IDFA (ios). Without this technical information we cannot find the user and therefore comply with the revocation request.

INFORMATION RETENTION

We retain personally identifiable information we process on behalf of our partners for as long as necessary to fulfil the purposes for which the data was collected and to provide services to them. We retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

END USER RIGHTS

If you reside in the EU or in a different jurisdiction that affords you with the below rights, you may contact us at legal@gurutraff.com and request to:

  • - Receive personal information;
  • - Request rectification of your personal information;
  • - Request the removal of your personal information;
  • - Object to the processing of personal information by us;
  • - Request to restrict processing of your personal information by us.

These rights are not absolute and requests are subject to any applicable legal requirements We may not be able to exercise your request in the event we cannot identify you.We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

SECURITY

We have implemented reasonable security measures in order to protect your information from loss, misuse and unauthorized access, disclosure, alteration or destruction. We cannot guarantee warrant or represent that your account or any of your information will be protected against loss, misuse or alteration. We make all reasonable efforts to prevent such occurrences.

INTERNATIONAL TRANSFERS

We may transfer the information we collect about you to countries other than the country where we originally collected the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy and take steps, where necessary, to ensure that international transfers comply with applicable laws.

CHILDREN INFORMATION

We do not knowingly collect any personally identifiable information relating to children under the age of 13. We require our Publishers to certify that their services are not primarily directed to appeal to children under the age of 13, and to avoid sharing with us any personally identifiable information relating to children under the age of 13. Our publishers are responsible to ensure that their privacy practices comply with applicable privacy laws and requirements. If you have knowledge of any incident in which we may be unknowingly collecting personally identifiable information relating to children under the age of 13, or that our SDK is included in any service that is directed to or aimed to appeal to an audience under the age of 13, please let us know immediately by contacting us at legal@gurutraff.com and we will cease such collection and/or appeal without delay.

CHANGES TO OUR PRIVACY PRACTICES

We may update this Policy to reflect changes to our privacy practices, from time to time. If we make any material changes we will post such change on our website, prior to the change becoming effective. Material changes will become effective seven (7) days as of the date we posted the change on our website. We encourage you to periodically review this page for the latest information on our privacy practices.

ANY QUESTIONS OR COMMENTS

The data controller responsible for your personal information for the purposes of the applicable European Union data protection law is:

Gurutraff LTD
ATTN : Data Protection Officer,
11 Ha-Sadna`ot St, Herzliya, Israel 4672408, IL
Email: legal@gurutraff.com

If you have any questions about this Privacy Policy or our data collection practices, please contact us at the address or email listed above and specify your country of residence and the nature of your question.