Tokabot Data controller Privacy

Tokabot Privacy Notice

We at Tokabot Ltd. (“Tokabot” “us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our customers and, as a result, we have established this Privacy Policy. Your ability to make informed choices about the uses of your information is important to us. This Privacy Notice describes the types of information we collect from you when you use our Chatbot (the “Bot”) and participate in and/or receive any of the services provided through the Bot, including provision of sports-game information, sports news, sports related trivia, challenges, surveys, and more (collectively, the “Services”). This Privacy Notice also explains how Tokabot may use, transfer, store, and disclose the information collected, as well as your ability to control certain uses of the collected information.  “You” means any adult user of the Bot and/or Services, using the Bot and/or Services on behalf of an entity, individual, company, or yourself.

Tokabot Ltd. is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is Derech Habsamim 1 Ganei Tikva  and our company registration number is 515680965

Privacy Notice Key Points

 

The following key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.

 

  • Personal Information We Collect. When you use our Bot and/or Services, we collect your basic profile information from Facebook. We also collect information about your use of the Bot and Services. If you contact us for questions or complaints, we will collect the information related to your inquiry.
  • Basis for Processing Your Personal Information. Processing your Personal Information is necessary for the provision of the Services to you. Processing for the purposes of developing and enhancing our products and Services, for analytics and usage analysis, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
  • Using the Information We Collect. We use the information we collect mainly to administer and provide the Bot and Services, contact you with administrative information, contact you with marketing offers, subject to your consent as may be required by applicable law and improve our Bot and Services.
  • Sharing the Personal Information We Collect. We may share the Personal Information we collect with our service providers and subcontractors who assist us in the operation of the Bot and Services and process the information on our behalf and under our instructions, as well as with our business partners and affiliates who may offer you personalized content and advertisement through our Bot.
  • International Transfer. We may use service providers and/or subcontractors located in countries other than your own, and send them your Personal Information. We will ensure to have agreements in place with such subcontractors and service providers ensuring the same level of privacy and data protection as set forth in this Privacy Notice.  You hereby consent to such international transfer.
  • Your Rights. Subject to applicable law, you may have a right to access, update or delete your Personal Information and obtain a copy of the Personal Information we have collected about you. You also have the right to object to certain processing, including the right to object, at any time, to processing your Personal Information for marketing purposes.
  • Retention. We retain information for as long as necessary for the purposes set forth in this Privacy Notice.
  • Security. We implement measures to reduce the risks of damage and unauthorized access or use of information, but they do not provide absolute information security.
  • Changes to the Privacy Notice. We may change this Privacy Notice from time and shall notify you of such changes.

 

Information We Collect

 

We collect information from you when you choose to use our Bot and/or Services.  In order to use our Bot and/or Services, you must have a valid Facebook account.  We may collect certain Personal Information (as defined below) when you make use of the Bot and/or Services, request information from us, or contact us for any other reason.

 

Personal Information” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. Examples of the Personal Information that we collect from you may include your name and certain personal preferences you have selected based upon your personal interest in sporting events and teams. We also collect information made available to us by Facebook. We recommend that you review Facebook’s policies prior to using our Bot and/or Services.

 

It is your voluntary decision whether to provide us with any such Personal Information, but if you refuse to provide such information you may not be able to use the Bot and/or Services.

 

How We Use Information

 

General

 

Tokabot and any of our trusted third-party subcontractors and service providers may use the information we collect from and/or about you and the information you input to the Services for any of the following purposes: (1) to respond to your inquiries or requests, contact, and communicate with you; (2) provide you with the Services, including customer support, where relevant; (3) develop new products or services and conduct analyses to improve our current content, products, and services; (4) subject to applicable law, provide you with customized content and targeted offers, and advertising on the Bot or through the Services on other third-party sites or apps you may visit, or via e-mail; (5) review the usage and operations of our Bot and Services; (6) use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (7) prevent fraud, protect the security of our Bot and/or Services, and address any problems with the Bot and/or Services; and (8) maintaining records as permitted under applicable law and protecting our legal rights.

 

Statistical Information

By analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and customer-needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Information. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.

 

Analytics

We may use certain analytics tools (“Analytics Tools”) to collect information about the use of the Bot and/or Services. Such Analytics Tools collect information such as how often users visit the Bot, what pages they visit when they do so, and what other sites they used prior to using the Bot. We do not combine the information collected through the use of the Analytics Tools with Personal Information. We use the information we get from Analytics Tools only for purposes of our Bot and Services.

 

Legal Uses

We may use your Personal Information as required or permitted by any applicable law.

 

Disclosure of Information

 

We may share your information, including Personal Information, as follows:

 

Business Partners, Service Providers, Affiliates and Subcontractors

We may disclose information, including Personal Information we collect and/or receive from and/or about you to our trusted service providers, business partners, affiliates and subcontractors, who may use such information to: (1) help us provide you with services; (2) aid in their understanding of how users are using our Bot and Services and improve the Bot and Services; and (3) subject to your consent as may be required under applicable law, provide to you personalized content and advertising through our Bot.

 

International Transfer

We may use subcontractors and service providers who are located in countries other than your own and send them information we receive (including Personal Information). We will ensure that these subcontractors and service providers will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice.  You hereby consent to such international transfer.

 

Business Transfers

We may transfer our databases containing your Personal Information if we sell our business or part of it.

 

Law Enforcement Related Disclosure

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Information with third parties:  if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Privacy Notice), (ii) to protect the rights, property or safety of third parties, (iii) when required by law, regulation subpoena, court order or other law enforcement related issues, or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Information as specified herein by emailing us at football@tokabot.com.

 

Other Uses or Transfer of Your Information

We allow you to use our Bot and Services in connection with third-party services, sites, and/or applications (including but not limited to Facebook). If you use our Bot and/or Services with or through such third-parties, we may receive information (including Personal Information) about you from those third parties and/or such third parties may collect and have access to your Personal Information. Please note that when you use third-parties outside of our Bot and/or Services, their own terms and privacy policies will govern your use of those services.  

 

How We Protect Information

 

We make efforts to follow generally accepted industry standards to protect the Personal Information submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially-acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

 

How to Access and Limit Our Use of Certain Information

 

You have certain rights in relation to the Personal Information that we hold about you, as detailed below. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:

 

  • Right of Access and Data Portability. You have a right to know what Personal Information we collect about you and, in some cases, to have the Personal Information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Information you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request us to) transmit such Personal Information to another party. If you wish to exercise this right please contact us letting us know what information in particular you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide all the information you ask for, for instance if the information includes Personal Information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
  • Right to Correct Personal Information. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Information and/or have us suspend the use of Personal Information, the accuracy of which you may contest, while we verify the status of that Personal Information. We will correct your Personal Information within a reasonable time from the receipt of your written request thereof.
  • Deletion of Personal Information. In certain circumstances you have a right to have Personal Information that we hold about you deleted. Should you wish to have any Personal Information about you deleted, please contact us using the information below. Subject to applicable law, we will delete Personal Information provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected information. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Information, you should also terminate your account with us. We may retain certain Personal Information (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
  • Direct marketing opt out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. If you do, please notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
  • Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Information, including for the purpose of direct marketing.
  • Account Deactivation. You may deactivate your account through the Bot by clicking the button marked “Unsubscribe.” In order to deactivate your account, we may ask you for additional information.
  • Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.

 

Data Retention

 

We retain information as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

 

Third Party Applications and Services

 

Portions of the Bot may involve linking to or using web applications or services belonging to third parties. The Bot may also provide you with links to access the applications of third party vendors or retailers. We have no control over third-party applications or services, and all use of third-party applications or services is at your own risk and subject to such third party’s privacy policies. Additionally, we cannot accept responsibility for any and/or services (including but not limited to payments processed or submitted through such third party applications), or for the privacy policies of any such applications and/or services. We are not responsible for content or available by means of such applications and/or services. We do not endorse any products or offered by third parties and we urge our users to exercise caution in using third-party applications and/or services.

 

Children

 

Tokabot does not knowingly collect personally-identifiable information from children under the age of sixteen (16).  In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.  

 

Communications

 

Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You may remove your Personal Information from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at football@tokabot.com.  You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send, as well as through your account settings.  Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications you may cancel your account.

 

Changes

 

When using our Bot and Services, you shall be asked to accept the terms of this Privacy Notice.  If you do not agree with the terms hereof, please do not use the Bot and/or Services. We may update this Privacy Notice from time to time – in which case, we shall notify you of such changes. We will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.

 

Comments and Questions

 

If you have any comments or questions about our privacy policy, or if you wish to exercise any of your rights, please contact us at football@tokabot.com.

 

Last updated: April 2018