Last modified on: [September] [19], 2024
Tedooo Privacy Policy
MA Tedooo group Ltd.,(the “Company”, and also in this policy "we", "us", "our") offers,
through [name of Application] web and application (the "Application"), a marketplace
for buyers and sellers for various products (“Products”),Products (“Services”).
This Privacy Policy is intended to explain how we collect, use and otherwise
process information collected from users, whether these are buyers or sellers (buyers
and sellers collectively "User/s"; and also "you") through the Application and website
and during the provision of Services. This policy is a part of the Terms
[https://www.tedooo.com/eula] and is incorporated therein. Capitalized terms used
in this Policy but not defined herein are defined in the Terms.
The Application and Services are intended for adults. Users under the age of eighteen
(18), or of legal age at their place of residence, are not permitted to use the
Application and Services without the consent of a parent or legal guardian. We have
the right to implement age verification measures, and to subject the right to
download and use the Application to pass such verification. Data privacy is
important to us. This means that we process data with due care, while adopting and
combining industry standard data collection, storage, and processing practices with
security measures to protect against unauthorized access, alteration, disclosure, or
destruction of a User's personal information and always in accordance with applicable
data protection laws.
Contents:
1. What personal data we collect (“Personal Data”)
2. How we collect your Personal Data
3. How we use your information
4. How we share your information
5. Data transfers and global processing
6. How long we hold your Personal Data
7. Marketing Messages
8. Data Subject Rights
9. Changes to This Privacy Policy
10. How to Contact Us
1. What Personal Data We Collect
1.1. We may collect different categories of personal information depending on
your activities on the Application and depending also on whether you are a
buyer or a seller:
1.1.1. When registering to the Application: name, postal address, email
address, telephone number, username, password. If you choose to
register through an existing account of yours in a different platform,
such as Google account, Apple account or Facebook account- your
username and password to such a platform will be used to enter
the Application, but be saved in an external service.
1.1.2. When you use the Application: the personal data that may be
contained in any video, photo, free text, comment or other
submission you upload or post to the Application; audio, visual
data, GPS location, information collected from devices GPS,
camera and microphone, such as location, sounds and images. We
strongly advise you not to include any sensitive information in the
free text you insert to Application, for example to your profile, Chat
or Feed.
1.1.3. Your entries in the various fields. Some of this data may be inserted
in the form of free text. We strongly advise you not to include any
payment data in such content (i.e. credit card numbers).
1.1.4. When payments are made by you, your payment information is
processed by third party payment processing services – we do not
collect or store this information.
1.1.5. When you interact with us outside the Application, we may also
collect details of other interactions that you have with us, together
with any other information that you choose to provide us with, for
example, through your interactions with our customer and technical
support teams.
1.1.6. Recording of User Activity - We may implement measures within our
platform to record user activity, including the use of tools which
captures detailed session data such as clicks, scrolling, and other
interactions within the application. This recording is utilized to
monitor and analyze how the platform is used, helping us improve
our services and user experience.
1.2. We also anonymize and aggregate personal information (so that it does
not identify you) and use it for purposes including testing our IT systems,
research, data analysis, improving the Application, and developing new
products and services. Such anonymized information includes technical
information transmitted by User's device regarding the hardware
specifications (e.g. operating system type, version and device) and
language preferences, as well as User's country.
1.3. You are not obligated to provide us with any of the above information
under any applicable law. However, we will not be able to operate the
Application and/or provide you with the Services or part of them, as
applicable, if you do not agree, or if you withdraw your consent, or request
to object (all as detailed under section 8 with respect to your rights) to our
processing of these data items. Therefore, if you do not agree to us
collecting the above Personal Data, please do not use the Application or
Services.
2. How We Collect Your Information
2.1. We collect Personal Data Directly: from Users when they register on the
Application or website and through their continuous use of the Application
or website.
2.2. We collect Personal Data Automatically - We automatically log information
about Users when they access our App and/or Website. For example,
when visiting our Application and/or Website, we log Users Device
operating system name and version, manufacturer and model, browser
type, browser language, how long they spent on a our application or
website… most of the data that is collected is deleted within 24 hours after
collection.
2.3. We collect Personal Data from Social Networking Site or other platforms
or websites- Our Application and/or Website includes interfaces that allow
Users to connect with social networking sites (each a “SNS”). If you
connect to a SNS through our Application and/or Website, you authorize
us to access, use and store the information that you agreed the SNS could
provide to us based on your settings on that SNS. We will access, use and
store that information in accordance with this Policy. You can revoke our
access to the information you provide in this way at any time by amending
appropriate settings from within your account settings in the applicable
SNS.
3. How we Use Your Information
Here is what we do with your Personal Data that we collect as described above:
1. We use all of the above personal data to operate, maintain, and provide to
you with the Application features and functionality and to provide you with
the Services as requested by you.
2. We use your information to send you emails with regards to your operation
of the Application (e.g.,account verification, notify you of changes/updates
to features, credentials change, technical and security notices), as well as
to send you marketing communications (please see more details
regarding this under “Marketing Communications”).
3. We may use the above information to respond to your requests and
messages, including with respect to your rights as data subject, as well as
to initiate contact with you on issues related to the Application or Services
or support and maintenance issues.
4. We may use the information you provide to allow certain functions to
perform as intended.
5. To prevent, detect and fight fraud or other illegal or unauthorized activities
6. We use anonymized, aggregate data, in order to gain insight on how you
and other users use the Application and Services and try and improve our
Application and Service, as well as to plan our marketing and
advertisements.
7. To ensure legal compliance – from our side (to legal requirements that
apply to us and to our obligations under the Terms) and from your side
(Compliance with laws applicable to you and with the Terms)
8. We will not use your Personal Data for any personal profiling and
automated decision making based on such profiling.
9. We limit access by our employees to your information only to those who
were specifically authorized by us to access your information, as part of
their job description.
4. Our Legal Bases for Processing:
With respect to such activities we will conduct as Controllers, we will only
process your personal information where we have a legal basis to do so.
The following are the legal bases under which we process your information in the
manners specified above:
1. Performance of a contract to which we and you, the data subject, are parties.
Many of the uses described above are actions that involve processing of your
information in order to meet our undertakings to you and respond to your
requests and indications within the Services.
2. Legitimate interests: We may use your information where we or our customers
have legitimate interests to do so. For instance, we analyze users’ behavior on
our services to continuously improve our offerings, and we process information
for administrative, fraud detection and other legal purposes.
3. Consent – some of the information you provide is based on your consent and will
to provide it. In addition, we may ask you from time to time, through the Service
or Application interface, to provide your consent for specific uses (for example, to
add you to our newsletter or send marketing communications to you in case we
have never had any commercial relations regarding the products or services
subject matter of such communication).
5. How we Share Your Personal Data
1. No Sale to Third Parties. We do not, and will not, sell any of your
personal data to any third party for advertising, marketing or any other
purpose – including your name, address, email address or credit card
information. We want to earn and maintain your trust, and we believe this
is absolutely essential in order do that.
2. Service Providers: we employ other companies services and technology
to perform tasks on our behalf and need to share some of your information
with them in order to provide the Services. The categories of third party
recipients of the Personal Data from us are as follows:
● Cloud and hosting – Amazon servers
● Translations service provider- Google, Microsoft
● DB – Mongo
● Signup and log in authentication- TWilio
● Analytics and attribution provider – Adjust
● Billing, processing payments – Google Pay and Apple Pay
● Sending push notifications – Pushi, Google and apple [yes]
● clearing service provider- Google, Apple [yes]
Our agents do not have any right to use your personal information collected from our
Services beyond what is necessary for the purpose of facilitating our provision of the
Application and Services.
3. Compliance with the Law: We may disclose your information if we
believe it’s necessary in order to comply with the law, such as to comply
with a subpoena, regulation or legal request, respond to a government
request, to address fraud or security issues, to protect the safety of any
person, to enforce our agreements with you; to investigate, prevent, or
take other action regarding illegal activity, suspected fraud or other
wrongdoing or to protect our own rights or property. If you are located in
the EU, we may only do so based on legal requirements specified above
of EU authorities. This includes sharing such information with our legal
counsels.
4. Business Transfers: If we are in a bankruptcy, merger, acquisition,
reorganization or sale of assets, your information may be transferred as
part of that transaction to a successor in interest and to the applicable
legal authorities as well as legal counsels and other professional counsels
involved such as accountants, and other officers of the government or of
the applicable judiciary instance.
5. Anonymized Information: We may provide third parties (for their needs,
including advertising and tracking) with aggregated but anonymized
information and analytics about our customers however, before we do so,
we will make sure that it does not identify you.
6. Data Transfers and Global Processing
Why is Personal Data Transferred?
As we operate globally, we may on occasion allow your personal data to be accessed
and/or processed and from and/or transferred to countries other than your own location.
We may do this where data is accessed/processed:
1. By our service providers, for the purposes we specified above under the chapter
“How we Share Your Personal Data”.
2. By consenting to the collection and use of your personal information, you agree
to your personal information being transferred and stored in this manner and for
the specified purposes.
Our Legal Basis for performing such transfers across boundaries (when we act as
Controllers):
1. Model Clauses. With some of our processors, we use standard contractual
clauses that are binding standards of processing of personal data committed
contractually by third parties processing information for us and on our behalf,
such standard clauses are approved by the European Commission.
2. Consent. In the absence of Model Clauses, Your consent. By using the
Application and/or Services, you agree and understand that your information may
be transferred from the EEA or other countries in which you may be using the
Services, to other countries outside your own location (including outside the
EEA), and specifically to the USA. The transfer will be to such third parties as
described under “How we Share Your Personal Data”. You agree to such
transfer, and you understand that data processed in these countries/regions is
subject to different data protection laws, which may sometimes grant a lesser
degree of protection than the privacy laws and regulations applicable within the
EEA for example.
7. How long we hold your Personal Data
We retain the personal information that we collect from and about you for as long as it is
needed to provide access to the Application or to manage your account. We take
reasonable steps to delete the personal information we collect if your registration to use
our Application lapses, if you opt out of receiving further communications from us, or if
you ask us to delete your information. We may however retain and use personal
information as necessary to comply with our legal and regulatory obligations, to resolve
disputes and to enforce our agreements, and we may retain and use anonymous and
aggregated information for performance reporting and analytic purposes and for product
and service improvement.
You can request that your personal information be deleted by contacting us at
[info@tedooo.com]
8. Security of Personal Data
We are committed to protecting the security of any personal data on our database and
network. We use a variety of security technologies and procedures to help protect all
personal data from loss, misuse, unauthorized use, access, inadvertent disclosure,
alteration and destruction. However, no network, server, database or Internet or e-mail
transmission is ever fully secure or error free. Therefore, you should take special care in
deciding what information you disclose.
9. Marketing Messages
1. If you have said we can, we will send you marketing messages by email to keep you
aware of what we’re up to and to help you see and find our products and services.
2. You can stop receiving marketing messages from us at any time. You can do this by
clicking on the ‘unsubscribe’ link in any email or by contacting us.
10. Data Subject Rights
You, as a data subject have a few rights relating to your personal data held or
processed by us:
1. The right to be informed about how your personal information is being used.
2. The right to access the personal information we hold about you.
3. The right to request the correction of inaccurate personal information we hold
about you.
4. In some circumstances, the right to request that we delete your data
5. The right to Restrict processing your personal data
6. The right to object to processing activities, if the processing is based on our
legitimate interest;
7. The rights to withdraw consent at any time, if the processing is based on consent
8. The right to object to processing of personal data for direct marketing purposes
9. In some circumstances, the right to request that we transfer or port elements of
your data either to you or another service provider – if the processing is based on
your consent, and is made by automated means.
10.The right to file a complaint with your Supervisory Authority.
11. Links to Other Websites
Our Application may contain links to third party applications, websites and features. This
Privacy Policy does not cover the privacy practices of such third parties. These third
parties have their own privacy policies and we do not accept any responsibility or
liability for their applications, websites and features or policies. Please read their privacy
policies before you submit any data to them.
12. Changes to This Privacy Policy
We may change this privacy policy from time to time, to reflect how we are processing
your data, including following any regulatory changes or our internal policies. If we make
significant changes, we will make that clear on the Application or by some other means
of contact such as email, so that you are able to review the changes before you
continue to use the Application.
13. How to Contact Us
We always want to hear from you!
Please don’t hesitate to contact us at info@tedooo.com, and we will be happy to answer
any questions you may have concerning this privacy policy, deal with your complaint, or
help you exercise any of your rights as set out above.
