11SHEEP PRIVACY POLICY
Last updated: May 31, 2018
Our Commitment
to You
11Sheep LTD (“11Sheep”) are dedicated to providing users with the highest level of
transparency and control over the use of their data. In order for us to provide
you with our services we are required to collect and process certain personal
information about you and your activity.
By entrusting us with your information, we would
like to assure you of our commitment to keep such information private. We have
taken measurable steps to protect the confidentiality, security and integrity
of this Information. We encourage you to review the following information
carefully. In this policy you can read about:
Contents
Grounds for data
collection. 1
How do we receive data about
you?. 1
What type of data we collect?. 2
Tracking Technologies. 2
How do we use the data we collect?. 3
With whom do we share your
Personal Data?. 4
Transfer of data outside
the EEA.. 5
How we protect your
information. 5
Retention. 5
EU User Rights. 5
How to contact us?. 6
Our Policy toward Children.
6
Updates to this Policy. 6
Grounds for
data collection
Processing of your “Personal Data” (meaning any
information which may potentially allow your identification with reasonable
means) is necessary for the performance of our contractual obligations towards
you and providing you with our services and the operation of our website and
apps (hereinafter the “Services”, “Website” and "App" respectively),
to protect our legitimate interests and for compliance with legal and
regulatory obligations to which we are subject.
When you use our Services, you consent to the
collection, storage, use, disclosure and other uses of your Personal
Information as described in this Privacy Policy.
How do we receive
data about you?
We receive your Personal Data from various sources:
1.
When you
communicate with us - For example when you send us an email, we collect the
Personal Information you provided us with.
2.
Technical
information - When operating our Services, we use various technological
tracking tools to collect information regarding your use of the Services in
order to provide them and improve your experience. Along with our partners, we
may use tracking technologies such as cookies, JavaScript, beacons and Local
Storage such as HTML5, which are used to store content information and
preferences. You can learn more about the tracking tools by reading the
Tracking Technologies section below.
3.
Third party
information – We may receive your data from third party providers who help us
with the provision and maintenance of our Services, such as social networks
(for example your name and user name, when you register or log-in to our
Service), traffic analytics vendors, fraud prevention agencies and others.
What type of
data we collect?
Personal Data
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 Policy. We collect the following Personal
Data about you:
·
Registration
information – we collect your name and if you connect your account to a social
network (for example: if you log in via Facebook or Twitter), we will also
collect certain details, such as your Facebook or Twitter account ID.
·
When using
our Services – our webserver will collect your device identifier and name, as
well as your Google Play ID or iOS Gamecenter ID.
Non-Personal Data
We also collect data about the use of our Service
and the characteristics and activities of users, in order to operate it and
improve it. We may collect the following non-Personal Data:
·
Technical
information – this category may include data such as your device type, device
model, device language preferences, the browser you are using and its display
settings, your operating system, session start/stop time, time zone, network
connection type (e.g., Wi-Fi, cellular), cookie information and your general
location (country).
·
Information
from third parties – this category includes information we receive from our
business partners. This may include pseudonymous advertiser identifiers that
some Advertisers or other third party ad platforms
choose to share with us. This information is also used to enhance data points
about a particular unique browser or device.
If we combine Personal Data with non-Personal Data,
the combined data will be treated as Personal Data. Further Personal Data will
only be stored and processed if you voluntarily provide it to us, e.g. through
a contact form.
Tracking
Technologies
When you visit or access our Services we use (and
authorize 3rd parties to use) SDKs, pixels, cookies, and other tracking
technologies (please visit our Third
Parties Page for more information). 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 Service's performance, perform analytics and customize
your experience. In addition, we may merge information we have with information
collected through these tracking technologies with information we may obtain
from other sources and, as a result, such information may become Personal Data.
We also use a tool called “Google Analytics” to
collect information about your use of the Services. Google Analytics collects
information such as how often Users access the Services, what pages they visit
when they do so, etc. We use the information we get from Google Analytics only
to improve our Services. Google Analytics collects the IP address assigned to
you on the date you visit, rather than your name or other identifying
information. 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
our Services is restricted by the Google Analytics Terms of Use and the Google
Privacy Policy.
How do we use
the data we collect?
·
Provision of service
- for the provision and improvement of our Services, including for support and
to respond to your queries.
·
Service
announcements - we will use your Personal Data to communicate with you and to
keep you informed of our latest updates to our Services and offer you service
offers.
·
Marketing and
advertising purposes - We may use your Personal Data in the following ways: we
may send you promotional material concerning our Services, or our partners'
services, which we believe might interest you; we may also display certain
adverts on our Services, which we believe will be relevant for you. We make our
best efforts to make sure you see only relevant ads and receive relevant
communications from us, including but not limited to, by building an automated
profile based on your Personal Data. You may however choose not to receive our
promotional or marketing emails (all or any part thereof) by clicking on the
“unsubscribe” link in the emails that you receive from us. Please note that
even if you unsubscribe, we may continue to send you service-related updates
and notifications, or reply to your queries and
feedback you provide us. You may also object to the use of your Personal Data
for advertising purposes by disabling your cookies, as described in the above
Tracking technologies section.
o
Opt-out of
receiving marketing materials - If you do not want us to use or share your
Personal Data for marketing purposes, you may opt-out in accordance with this
"Opt-out" section. Please note that even if you opt-out, we may still
use and share your Personal Data with third parties for non-marketing purposes
(for example to fulfill your requests, communicate
with you and respond to your inquiries, etc.). In such cases, the companies
with whom we share your Personal Data are authorized to use your Personal Data
only as necessary to provide these non-marketing services.
·
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 Services 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 11Sheep, its users
and/or partners.
·
Enforcing of
policies - we may use your Personal Data in order to enforce our policies,
including but limited to our Terms.
·
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.
With whom do we
share your Personal Data?
·
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. For more information
about third parties, please visit our Third
Parties Page.
·
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 data in accordance with the terms of this
Privacy Policy.
Transfer of
data outside the EEA
Please note that some data recipients may be
located outside the EEA. In such cases we will transfer your 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 isn’t 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 and
limiting access to your account. You will be solely responsible for all use of
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 service, 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 client personal data, trading information, account
opening documents, communications and anything else as required by applicable
laws and regulations.
EU User Rights
You may request to:
1.
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.
Receive a
copy of Personal Data you directly volunteer to us in a structured, commonly
used and machine-readable format.
3.
Request
rectification of your Personal Data that is in our control.
4.
Request
erasure of your Personal Data.
5.
Object to the
processing of Personal Data by us.
6.
Request to
restrict processing of your Personal Data by us.
7.
Lodge a
complaint with a supervisory authority.
However, please note that these rights pertain to
EU residents only, are not absolute, and may be subject to our own legitimate
interests and regulatory requirements. Users outside the EU are welcome to
contact us for any questions or requests at the details below.
How to contact
us?
If you wish to exercise any of the aforementioned
rights, or receive more information, please contact our Data Protection Officer
(“DPO”) using the details provided below:
11Sheep
Email: info@11sheep.com
Address:
Asher 57, Raanana, Israel
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 Services (as reflected in the "Last Updated" heading). You are
advised to check for updates regularly. By continuing to access or use our
Services after any revisions become effective, you agree to be bound by the
updated Privacy Policy.