PRIVACY POLICY

Phantom.me

[Last modified: February 4, 2019]

 

Phantom.me Ltd. (“Company” or “we” or “us” or “our“) is the sole owner and developer of the mobile application known as Phantom.me (“App”) providing a private zone on your mobile device allowing you to use various mobile features and Services (as defined and detailed in our Terms of Use. This privacy policy (“Privacy Policy”) discloses our processing practices and specifically how or why we collect, share and use our users' (“you” or “user”) data and governs your use of the App, Services and our website available at: http://phantom.me/.

Please note that, as the App is intended to provide you with a private zone, we DO NOT collect, use or process any information you choose to store on your device using the Services, nor any private communication made through the App.

This Privacy Policy is an integrated part of our Terms of Use (“Terms”). Definitions herein shall have the meaning assigned to them in the Terms.

This Privacy Policy governs the privacy practices of the Company, but before we would like to explain the lawful basis for processing data:

(i) If you contact us for support or any inquiry, we process your Personal Data (as defined below) you voluntarily provide (e.g., email, etc.) in order to perform our contract with you;

(ii) When visitors access our website or use our Services, we may collect Internet Protocol (“IP”) address which we have a legitimate interest in processing; or (iii) We will also process your Personal Data where you will provide us with consent to do so.

If you have any questions about this Privacy Policy, please contact us at: privacy@phantom.me.

AMENDMENTS

We reserve the right, at our discretion, to revise or update this Privacy Policy at any time. Such changes shall be effective upon publication of the amended Privacy Policy. The last revision will be reflected in the “Last Modified” heading. Your continued use of the App and Services thereafter constitutes your consent to such changes and you agree to be bound by them. Please make sure to review our Terms periodically. In the event of a material change we will make best efforts to provide written notification, subject to applicable law requirements.

THE TYPES OF DATA WE COLLECT AND PURPOSE OF USE

Depending on your interaction with us, we may collect two types of data from you, as follows:

(i) Non-identifiable information which may be made available or gathered through your use of the App and Services. To clarify, we are not aware of your identity due to such information (“Non-Personal Data”).

(ii) Individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”), this information includes solely information you voluntarily provide us when you, for example, contact us, and online identifiers such as IP addresses. The content below details the types of data we collect and how we use it:

What type of data we collect? How do we use it?

When you access the website, App or use the Service, we will collect Non-Personal Data - meaning technical, aggregated data that cannot identify you, such as the type of browsers; type of operation system; type of device; time and date of access the website or App; language preference; approximate location (extracted from the IP collected, as detailed below). We use this data solely to provide and enhance our Services and to enable operation of the App.

When you download our App, we will collect your Machine Generated ID (“MID”). We will use this for validation purposes. Note that, as we provide secure and private network, we do not store or obtain any copy of the information you store using the App and are not aware to your communications made via the App, rather it will be stored on your device or backed up in your own Google Drive accounts provided through registration.

When you use our Services, will collect your IP addresses. We use the IP in order to provide and operate the Services, as well as to detect security and technical issues. If you voluntarily contact us, you may be required to provide us with certain information such as your name and email address.

We will use this data solely to provide you with the support you have requested or respond to your inquiry. We provide you with a free version of the App. However, Premium Services are available only for Paid Subscription. Any and all payments are made through Google Play and are subject to Google Play’s terms and privacy policy.

Please see the Google Play Privacy Policy for more information: https://policies.google.com/privacy?hl=en&gl=il.

HOW WE COLLECT INFORMATION

We collect the data detailed above, in the following ways:

● Automatically, when you interact with our App and website (meaning IP address and technical Non-Personal Data); or

● When you voluntarily choose to provide us with information, i.e. when you contact us.

COOKIES

When you interact with our Services, we may use “cookies” (or similar technologies), which store certain information on your device (i.e., locally stored) and which we will use for internal statistics in order to improve the Services. The use of cookies is a standard industry-wide practice. Cookies are very helpful and can also be used for making the interaction between you and our Services quicker and easier.

We use Google Analytics cookie and Google Firebase to collect information about online usage activities across our website and Services. This data may include IP address. To learn more how Google uses data from our use of Google services we recommend you review Google’s policies located at: www.google.com/policies/privacy/partners and https://policies.google.com/technologies/partner-sites. We also encourage you to review the Google Analytics' currently available opt-outs for the web tool available at: https://tools.google.com/dlpage/gaoptout/.

You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set, by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful: Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera.

SHARING DATA

We will not share your Personal Data with third parties, except in the specific events detailed below, when we will believe it is necessary, and solely to the extended needed (note that, the Personal Data does not include the information you save in the App or your communications through the App as we do not store nor obtain a copy of such information):

● User’s explicit consent - we may disclose your Personal Data to third parties upon your explicit consent or to your request. Please note that once we share your information with third party, that information becomes subject to the other third party’s privacy practices.

● Policy and Law enforcement - we may disclose or share your Personal Data, solely to the extent needed to enforce our policies and to exercise our legal rights.

● Third party rights - we may share your Personal Data in order to prevent breach of third party rights.

● Affiliate company and corporate transaction- we may disclose or share your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under common control (" Affiliated Companies ") solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of a corporate transaction.

● Service Providers - we may share Personal Data to our service providers to perform requested services on our behalf, e.g., servers’ provider, in-app payment processors, etc.

DATA RETENTION

We retain the Personal Data we have collected (and solely as detailed in the table above) for as long as needed to provide the Service, carry out our business purpose and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed below.

USERS’ RIGHTS & CONTROLS

Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Data. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Data they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Data to another party. For more information, please review our User Rights Overview.

We provide you with the ability to exercise certain choices and controls in connection with our processing of your Personal Data, depending on your relationship with us. If you wish to exercise any or all of the above rights, please download our applicable form available at: Data Subject Request Form and send it to our privacy email at: privacy@phantom.me.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) or as otherwise required under applicable law.

Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

SECURITY OF THE DATA

We take great care in implementing and maintaining the security of the App, Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information and prevent unauthorized use of any such. We have implemented technical, physical and administrative security measures to protect the Personal Data. The data collected by us is stored in AWS data servers in the EU, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security/. For additional information regarding our security measures please review our Information Security Overview.

Further, in the event of a data incident, in which we discover your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).

TRANSFER OF DATA

If you visit our App or use our Services, please note that any information processed by us, as detailed in this Privacy Policy, may be transferred to and processed in countries other than the country from which you accessed our Services. If you are a resident of the EEA, we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction, where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

CHILDREN PRIVACY AND DATA

The Services are not intended for children under the age of 18 years old. Accordingly, we do not use the Service to knowingly solicit data from children under the aforesaid age and we request that children under the age of 18 do not provide Personal Data through our Services. If you become aware or have any reason to believe that a child has shared any information with us, please contact us at privacy@phantom.me and we take reasonable steps to ensure that such information is deleted from our files.

DO NOT TRACK DISCLOSURE

The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/.

CONTACTING US

If you have any comments or questions about our Privacy Policy, please contact us at:

Phantom.me Ltd.

7 Shadal st.

Tel Aviv

Israel

DATA PROTECTION OFFICER

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: privacy@phantom.me.

Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.