Last Revised: March 26, 2018
Overtok Ltd. (collectively “Overtok”, “Company” “we” or “us”) develops and offers a proprietary technology enabling mobile and web end-users real-time communication means to connect with mobile and web operators who use the Overtok service via and API licensed by such operators and embedded into their mobile or web assets (the “Services”).
1. Your Consent – Please read carefully!
2. What Information Do We Collect?
In performing the Services we may collect two general types of information regarding our Users:
a. Un-identified and non-identifiable information pertaining to Users, which may be made available to us, or collected automatically via their use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the person from whom it was collected, and mainly consists of technical and aggregated usage information, such as the identity and operation system and browser, smart-phone version, operating system version, duration of usage of the Services, User’s ‘click-stream’ activity, keyboard language, etc.
b. Individually identifiable information, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of private or sensitive nature (“Personal Information”). Such Personal Information that is collected by us consists of the following types of information (including, for the avoidance of doubt, Non-personal Information that is connected or linked to said Personal Information to the extent such connection or linkage exists): IP address, personal details provided in connection with usage of the Services including name, e-mail address, phone number, address, portrait/photo, video/text/audio conversations you conduct or participate in, their record and transcript (if you have approved the authorized and lawful recording of such conversations), your interactions and networks, information about you that may be provided in video/text/audio conversations conducted by you, information about the persons which could appear in the video/audio/text conversations held between any other persons.
TO THE EXTENT THAT YOU PROVIDE TO US ANY PERSONAL INFORMATION IN CONNECTION WITH ANY THIRD PARTY, INCLUDING ANY OF YOUR CUSTOMERS OR END-USERS (COLLECTIVELY, THE “END USERS”) AND ANY PERSON WHOSE INFORMATION IS PROVIDED AS PART OF VIDEO/TEXT/AUDIO CONVERSATIONS OR OTHERWISE THROUGH YOUR USE OF THE SERVICES, YOU ARE SOLELY RESPONSIBLE TO RECEIVE AND HEREBY REPRESENT AND UNDERTAKE TOWARDS OVERTOK THAT YOU HAVE RECEIVED THE CONSENT, AUTHORITY, PERMISSION AND APPROVAL OF SUCH PERSON AND PROVIDED THEM WITH SUFFICIENT DISCLOSURES, TO ALLOW THE USE OF SUCH PERSONAL INFORMATION, AND TO ALLOW OVERTOK TO ACCESS, STORE, COLLECT, ANALYZE AND PROCESS SUCH PERSONAL INFORMATION FOR SUCH PURPOSES AS DETAILED HEREIN.
PLEASE NOTE THAT IN CONNECTION WITH THE RECORDING OF THE VIDEO/AUDIO CONVERSATIONS YOU CONDUCT OR PARTICIPATE IN THROUGH YOUR USE OF THE SERVICES, THERE ARE NOTIFICATION AND CONSENTS REQUIREMENTS, NECESSARY OR ADVISABLE UNDER APPLICABLE LAW. SUCH REQUIREMENTS MAY VARY FROM STATE TO STATE, AND COUNTRY TO COUNTRY. YOU ARE SOLELY RESPONSIBLE FOR COMPLYING WITH ANY AND ALL APPLICABLE LAWS IN CONNECTION WITH YOUR USE OF THE RECORDING FEATURE
3. How Do We Collect Such Information?
4. Why Do We Collect the Information?
5. Where Do We Store Personal Information?
Information regarding our Users may be maintained, processed and stored by Overtok and our authorized affiliates and service providers in the United States of America, in Israel, and in other jurisdictions as necessary for the proper performance and operation of the Services and/or as may be required by law.
6. Where Do We Store Personal.
Non-Personal and Personal Information of Third Parties Information?
To the extent Overtok processes any Personal Information on Your behalf when performing of the Services, You shall be deemed the data controller and Overtok shall be deemed a data processor, and in any such case: (i) You will collect, use, transfer and otherwise process any Personal Information collected by or through the Services in compliance with all applicable laws, enactments, regulations, orders, standards and other similar instruments, including but not limited to the data protection laws; (ii) You shall be responsible for providing appropriate information and obtaining any required consent from Your End Users, including notice and consent allowing it to own, control and transfer all Personal Information that is provided by End Users; and (iii) You have provided such information and obtained such consent to any processing of Personal Information by and through the Services in accordance with any and all applicable laws.
7. Minors and Eligibility
8. With Whom Do We Share Personal Information?
For avoidance of doubt, Overtok may transfer and disclose Non-personal Information including any aggregate or statistical to third parties at its own discretion.
9. Modification or Deletion of Personal Information
If you wish to exercise your right to access and/or request us to make corrections to your Personal Information that you have stored with us, please send us an e-mail to email@example.com and we will respond within a reasonable timeframe and in accordance with applicable laws.
Please note, upon request to delete your account, Overtok may depersonalize (and un-identifiable) your activity history for the purpose of enhancing and improving our Services.
10. Data Retention
We may retain Your or your End Users’ Personal Information for as long as your User account is active or as otherwise needed to provide you with our Services. We may retain such Personal Information even after you deactivate your account or you or your End User’s cease to use our Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding any of our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
Overtok has implemented security measures designed to protect the Personal Information of our Users, including, procedural and electronic measures. Among other things, we regularly monitor our systems for possible vulnerabilities and attacks, and seek news ways and tools for further enhancing the security of the Services and the integrity of the Personal Information that we hold.
Please note however, that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any Personal Information.
12. Third Party Sites
Overtok uses certain monitoring and tracking technologies, including ones offered by third party services. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide a better experience to our Users and their End Users. For example, these technologies enable us to keep track of our Users’ and their End Users’ preferences and authenticated sessions, to better secure our Services and detect abnormal behaviors, to identify technical issues, and to monitor and improve the overall performance of our Services
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device, for purposes of session and user authentication, security, keeping the User’s preferences, connection stability, monitoring performance and generally providing and improving our Services.
In order to delete or block any cookies, please refer to the “Help” area on your internet browser for further instructions, or look for optional third party add-ons offering cookie management assistance. For example, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. Please note however that deleting any of Overtok’s cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.