SHOMODJSAV  Privacy Policy

SHOMODJSAV cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how SHOMODJS LLC together with its affiliated companies worldwide (shomodjsav), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all SHOMODJSAV users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all SHOMODJSAV services, including our websites (including www.shomodjsav.com and any of its subdomains, the “Website”), web applications (“SHOMODJSAV Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws. Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us. This policy describes our privacy practices – what Personal Information we collect about our Users, what we do with it, how we share it, and your rights regarding that Personal Information. ​ By accessing or using any of our Services, you acknowledge that you have read this Privacy Policy. 2. What ‘Personal Information’ do we collect? 2.1. User information: To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you: Information you provide us. When you register for our Services, sign up for any SHOMODJSAV events, subscribe to our blog(s) or newsletter(s), purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., SHOMODJSAV, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents). Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns. To provide our Services, we collect Personal Information about our Users. The Personal Information comes from you when you visit or use our services, Personal Information we collect automatically, and Personal Information we collect from other sources. 2.2. Users of users ‘Personal Information’ We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section ‎6 below). 2.3. SHOMODJSAV jobs applicant information We also collect information that is provided to us by SHOMODJSAV jobs candidates (“Applicants”), when they apply to any of the open positions published at https://www.shomodjsav.com/jobs, by e-mail or otherwise (as further described in our Privacy Policy for Job Applicants). 3. Why do we collect such ‘Personal Information’ We use your Personal Information for the following purposes: To provide and operate the Services; .To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties; To provide our Users with ongoing customer assistance and technical support; To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below); To help us to update, expand and analyze our records to identify new customers; To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits; To analyze our performance and marketing activities; To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services; To provide you with professional assistance. To enhance our data security and fraud prevention capabilities; and To comply with any applicable laws and regulations. We may use techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (i) still have a human being involved in the process (and so are not fully automated); or (ii) use machine learning in ways that don’t have significant privacy implications (for example, reordering how applications might appear when you visit the SHOMODJSAV App Market). We may also use machine learning to help us monitor, identify, and suspend accounts sending spam, or engaging in other abusive or fraudulent activity. We use your Personal Information for the purposes set out in Section 3 where: Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support); Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of SHOMODJSAV by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights. We use the Personal Information we collect about you to provide our services and make them better and safer. ​ We also collect and use Personal Information in order to contact Users and to comply with the laws applicable to us. 4. How we share your ‘Personal Information’ We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances: Third Party Service Providers: SHOMODJSAV has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”). ​ SHOMODJSAV may share the following categories of Personal Information with Third Party Service Providers for a business purpose: identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers. commercial Personal Information, for example Personal Information regarding products or services purchased, obtained, or considered. 4.1. We may share the Personal Information of our Users and Users-of-Users with various third parties, including certain service providers and law enforcement officials. ​ The Personal Information may be shared solely in accordance with this policy. Law Enforcement, Legal Requests and Duties: SHOMODJSAV may disclose or otherwise allow access to any categories of your Personal Information described in this Privacy Policy pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. 4.2. Protecting Rights and Safety: SHOMODJSAV may share any categories of your Personal Information described in this Privacy Policy if we believe in good faith that this will help protect the rights, property or personal safety of SHOMODJSAV, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you. 4.3. SHOMODJSAV Subsidiaries and Affiliated Companies: We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. For example, we may share your Personal Information with shomodjsav.com, our US-based subsidiary, in the course of facilitating and providing you (and your Users-of-Users) with our Services. Sharing Personal Information by SHOMODJSAV subsidiaries and affiliated companies in the European Union, the United Kingdom and Switzerland with SHOMODJSAV’s subsidiaries located outside these regions will only take place under an approved transfer mechanism, such as the relevant Standard Contractual Clauses. 4.4. In connection with a change in corporate control: In addition, should SHOMODJSAV or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. 4.5. Upon Your Further Direction: The SHOMODJSAV Services enable you, through different techniques, to engage and procure various third party services, products and tools for enhancing your web or mobile sites, including, without limitation, applications and widgets offered to you by third parties through the SHOMODJSAV Website (including the Wix App Market), eCommerce payment providers, third party designers who may assist you with your website, etc. (collectively, “Third Party Services”). If you choose to engage with such Third Party Services, they may have access to and process Personal Information of your Users-of-Users collected through your web or mobile sites. For example: a) Framed Pages: our Services may enable you to integrate Third Party Services directly into your web or mobile sites, such as via page framing techniques to serve content to or from Third Party Services or other parties (“Frames”). In these circumstances, the Third Party Services may collect Personal Information from your Users-of-Users. b) App Market Developers: We allow third party developers (“Third Party Developer(s)”) to develop and offer their own applications via the Wix App Market (“Third Party App(s)”) to Users, which you may integrate into your web or mobile sites. Each Third Party Developer is bound by the SHOMODJSAV App Market Partner Agreement, which among other things, restricts the ways in which such developers may access, store, share, and use the Personal Information you and/or your Users-of-Users provide to them. c) Social Media Features: Our Services may enable you to integrate certain Social Media features, widgets, and single sign on features, such as “Facebook Connect,” or “Google Sign-in” (“Social Media Features”) into your web or mobile sites. These Social Media Features may collect certain Personal Information from your Users-of-Users such as identifiers, including name, alias, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers. Social Media Features are hosted either by a third party or directly on our Services. Please note that in the examples listed above in this Section 5, SHOMODJSAV merely acts as an intermediary platform allowing you to procure the services of such Third Party Services (including, but not limited to, Third Party Developers, Third Party Apps and Social Media Features) with which you are interacting directly, and at your discretion. In this respect, SHOMODJSAV acts as a service provider to you, disclosing information to the Third Party Services on your behalf. SHOMODJSAV will share your Users-of-Users’ Personal Information with Third Parties Services only upon your direction or with your permission and is not, and shall not be, in any way responsible for such Third Party Services processing of such Personal Information, or liable with respect thereto. SHOMODJSAV does not control and is not responsible for the actions or policies of any Third Party Service, and your use of any Third Party Service is at your own risk. We encourage you to review any privacy policy accompanying a Third Party Service and ask such Third Party Service for any clarifications you may need before deciding to install and/or use their services. 5. Where do we Store/Process your ‘Personal Information’? SHOMODJSAV processes data about individuals across the world and may transfer your Personal Information outside of your country. Your security, privacy and confidentiality are our top priority and that's why SHOMODJSAV conducts a vetting process that includes an assessment of the privacy laws in those countries to validate they have strong data protection laws. 5.1. Shomodjsav ’s data storage providers are contractually committed to protect and secure your data. With respect to Personal Information received or transferred pursuant to the Privacy Framework, shomodjsav.com is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In compliance with the Privacy Shield Principles, shomodjsav.com commits to resolve complaints about our collection or use of your personal information. E.U. and Swiss individuals with inquiries or complaints regarding our Privacy policy should first contact us at: service@shomodjsav.com For the avoidance of doubt, SHOMODJSAV does not rely on the Privacy Shield as a mechanism for transferring GDPR protected personal data. Currently, SHOMODJSAV only rely on other transfer mechanisms, as detailed above, such as the SCC or an adequacy decision. 5.2 6. Users-of-users’ ‘Personal Information’ SHOMODJSAV may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their email contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with SHOMODJSAV, on the User’s behalf. ​ For such purposes, SHOMODJSAV serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information. ​ The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions. ​ The Processing of the Users-of-users’ Personal Information shall take place within the territory of the European Union, Israel or a third country, territory or one or more specified sectors within that third country of which the European Commission has decided that it ensures an adequate level of protection and such processing and transfer will be in accordance to the Data Processing Addendum – Users (“DPA"). Any transfer to and Processing in a third country outside the European Union that does not ensure an adequate level of protection according to the European Commission, shall be conducted under an approved transfer mechanism, as detailed in the DPA. ​ You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information. ​ SHOMODJSAV cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them. ​ For more information on how Users-of-Users Personal Information may be handled by SHOMODJSAV (which may be relevant for any specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 4, 12 and 13. If you are a visitor, user or customer of any of our Users, please read the following: SHOMODJSAV has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by SHOMODJSAV on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If SHOMODJSAV is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR). Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below. SHOMODJSAV may collect and process Personal Information regarding the users of our users. We do this solely on our users’ behalf, and at their direction. Our users are solely responsible for their users-of-users information, including for its legality, security and integrity. SHOMODJSAV has no direct relationship with any of its users’ users. If you are a user-of-user, please contact the SHOMODJSAV site owner directly. 7. Use of cookies and other third-party technologies We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience. ​ You can learn more about how we use cookies and similar technologies and how you can exercise control over them in our Cookie Policy. ​ Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. We and certain third party services may use cookies and similar tracking technologies throughout our services. These technologies are used mostly for stability, security, functionality, performance and advertising purposes. 8. Communications from SHOMODJSAV 8.1. Promotional messages We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from SHOMODJSAV or our partners (acting on SHOMODJSAV’s behalf) through such means. ​ If you do not wish to receive such promotional messages or calls, you may notify SHOMODJSAV at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive. We may send you promotional messages and content. You can easily opt-out of receiving promotional messages by contacting us or unsubscribing. 8.2. Service and billing messages SHOMODJSAV may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services. ​ It is important that you are always able to receive such messages. For this reason, you are unable to opt-out of receiving such Service and Billing Messages unless you are no longer a SHOMODJSAV User (which can be done by deactivating your account). We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages. 9. Your rights in relation to your ‘Personal Information’ SHOMODJSAV believes that it is imperative that all SHOMODJSAV users have control over their Personal Information. Therefore, depending on the way you use the SHOMODJSAV Services, you may have the right to request access to, receive a copy of, update, amend or delete, port certain Personal information. 10. Contacting us If you have any questions about this Privacy Policy please contact us at service@shomodjsav.com. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.