This Privacy Policy describes how we – eTribez Labs Ltd. (together with our affiliated companies – “eTribez”, “we”, “our” or “us”) collect, store, use and disclose personal data regarding individuals (“you”) who: (i) visit or otherwise interact with our websites (“Visitors”), available at www.etribez.com, or any other website, webpage, e-mail, text message or online ad under our control (collectively – “Sites”); (ii) use our online SaaS platforms (the “Applicant” when individuals signing up to campaigns and the “Users” or “Customers” when concerning (employees of) customers of eTribez) via the Sites (the eTribez Casting Platform™ and eTribez Production Management Platform™, together with Sites – the “Services”). As part of the Services, a Customer opens a designated account (“Account”) through which it uses the eTribez Services and for which it appoints admin Users.
Specifically, this Privacy Policy describes our practices regarding:
1. Data Collection
2. Data Uses
3. Data Location & Retention
4. Data Sharing
5. Cookies and Tracking Technologies
6. Communications
7. Data Security
8. Data Subject Rights
9. Data Controller/Processor
10. Additional Notices
Your privacy is important to us, and we are strongly committed to making our practices regarding your personal data more transparent and fairer. Please read this Privacy Policy carefully and make sure that you fully understand and agree to it.
You are not legally required to provide us with any Personal Data (defined below), and may do so (or avoid doing so) at your own free will.
If you do not wish to provide us with such Personal Data, or to have it processed by us or any of our Service Providers (defined below), please simply do not enter our Sites or use our Services. You may also choose not to provide us with “optional” Personal Data, but please keep in mind that without it we may not be able to provide you with the full range of our services or with the best user experience when using our Services.
This Privacy Policy forms part of our Terms of Service (“Terms”).
1. Data Collection
We collect technical data, profile data, customer data, content, and other data received from you, your organization or other third party sources.
We collect various types of personal data regarding our Users and Applicants as well as data regarding Visitors to our Sites. Such data is typically collected and generated through your interaction with us or our Services, through automatic means, or directly from you, from our Customers, or from other third parties (including Service Providers, as hereinafter defined).
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “Personal Data“):
1. Data automatically collected or generated: When you visit, interact with, or use our Services, we may collect, record or generate certain technical data about you. We do so either independently or with the help of third party Service Providers (as defined in Section 4 below), including through the use of “cookies” and other tracking technologies (as detailed in Section 5 below).
Such data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device data (like type, operating system, mobile device id, browser version, locale and language settings used), date and time stamps of usage, the cookies and pixels installed or utilized on such device and the recorded activity (sessions, clicks and other interactions) of Visitors and Users in connection with our Services. In addition, phone calls (e.g. with our customer success or account management consultants) may be automatically recorded, tracked and analyzed, for purposes including analytics, service-, operations-, and business quality control and improvements, and record-keeping purposes.
2. Profile Data received from you: When you contact us or sign up to the Services and create your individual profile (“Applicant Profile”), you may provide us with Personal Data. This includes your name, contact details (such as e-mail, phone and address), login details (e-mail address and passwords which are automatically hashed), as well as any other data you choose to provide when you use our Services, contact us, or interact with others via our Services. You may also provide us with your profile photo, age, gender, location, personalized video, time-zone, skills, device, general location, and activity logs and data; as well as your preferences, characteristics and objectives for using the Services, dependent on the specific production you are signing up to (collectively, “Profile Data”).
You may also send us a “Contact Us” message, or provide us with feedback or reviews, or answers to surveys or promotions, including by submitting an online form on our Services or social media channels, by posting on any of our online public forums, by sending an e-mail to any of our designated addresses, or any other form of communication. Such data may include details on a problem you are experiencing, contact information and any other documentation, screen recording, screenshots or other information.
Our Customers may provide us with information such as their billing details, business needs and preferences (“User Data”). To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), we will not regard it as “Personal Data” and this Privacy Policy will not apply to it.
3. Customer Data containing Personal Data: Users may choose to upload or submit Customer Data to our Services which includes Personal Data (e.g., by uploading the Customer’s clients or employees directories ). Personal Data which is included in Customer Data will only be processed by eTribez on behalf of our Customer (who manages the Customer’s Account), in accordance with our agreements with such Customer, and this Privacy Policy.
4. Additional Data received from our Applicants/Users: Applicants/Users may provide us with the contact details of their respective colleagues or ‘team/family’ members, in order for us to contact, invite or subscribe them as Users/Applicants to our Services. Such data typically includes these individuals’ names, phone numbers and (work) e-mails, however additional data may be provided at the discretion of those providing it. For the purposes of this Privacy Policy, this data will also be regarded as “Profile Data” or “User Data”.
5. Data received from other third parties: We may receive Personal Data concerning you as an employee of our Customer from other sources. For example, we may receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or service providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities.
6. Data obtained through Analytics Tools: We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and Services. Analytics tools collect data such as how often Applicants, Users and Visitors visit or use the Sites or Services, which pages they visit and when, and which website, ad or e-mail message brought them there.
2. Data Uses
We use Personal Data to provide, improve and secure our Services; for analytics, marketing and sales purposes; to comply with applicable laws; and to support our legitimate interests.
We use Personal Data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services to you and others; providing customer service and technical support; and protecting and securing our Users, Customers, Visitors, ourselves and our Services.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use Personal Data for the following purposes:
- To facilitate, operate, and provide our Services;
- To authenticate the identity of our Applicants, and to allow them to access our Services;
- To provide our Visitors, Applicants, Users and Customers with assistance and support;
- To gain a better understanding on how Visitors, Applicants and Users evaluate, use and interact with our Services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
- To contact our Visitors, Applicants, Users and Customers (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section 6 below);
- To facilitate, sponsor and offer certain events, contests and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
- To comply with applicable laws and regulations
3. Data Location & Retention
We store your data in multiple locations around the world, for as long as necessary in accordance with our reasonable business needs (as necessary for the performance of our Services or for supporting and exercising our legitimate interests); and in accordance with our legal obligations.
Data Location: Your Personal Data may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the United States of America, Israel and other jurisdictions, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, eTribez and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
Data Protection in Israel: eTribez Labs Ltd. is headquartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
Data Retention: We will retain your Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@etribez.com.
4. Data Sharing
We share your data (& feedback) with our Service Providers; our Customers; within our group and in accordance with legal compliance.
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b)disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and services.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own. Such service providers include Third Party Service providers, hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal and financial advisors (collectively, “Service Providers“).
These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our agreements with them.
Our Service Providers shall be deemed as ‘Data Processors’ in circumstances where eTribez assumes the role of ‘Data Controller’; and where eTribez acts as the Data Processor for our Customer, the Service Provider shall be deemed our ‘Sub-Processor’ (as further described in Section 9 below).
Third Party Websites and Services: Our Services also include links to third party websites, and integrations with Third Party Services. Such websites and Third Party Services, and any information you process, submit, transmit or otherwise use with such websites and Third Party Services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and Third Party Services.
Sharing Personal Data with our Customers and other Users: We may share your Personal Data with the Customer managing the Account to which you are subscribed as an Applicant (including data and communications concerning your Applicant Profile). In such cases, sharing such data means that the Customer may access it, and will be able to monitor, process and analyze your Personal Data.
Any Customer Data or other content submitted by you to your User Profile may still be accessed, copied and processed by the relevant Customer(s). Your User Profile and User Data will also be made available to all the authorized Users who can view the same Profile(s) as you. Please note that eTribez is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the “Data Controller” of such data (as further described in Section 9 below).
Sharing your Feedback or Recommendations: If you submit a review or feedback, note that we may (at our discretion) store and present your (anonymous) review to other Applicants or Users of our Sites and Services (including other Customers). If you wish to remove your review, please contact us at support@etribez.com.
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of eTribez, any of our Applicants, Users or Customers, or any members of the general public.
eTribez Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group, for the purposes described in this Privacy Policy. In addition, should eTribez or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition, fund raising or purchase of its shares or assets, your Personal Data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
For the avoidance of doubt, eTribez may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
5. Cookies and Tracking Technologies
We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes.
Our Sites and Services (including some of our Service Providers) utilize “cookies”, anonymous identifiers, container tags and other technologies in order for us to provide our Services and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by an Applicant, User or Visitor. For more information, please review our Cookies 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.
6. Communications
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset notices, etc. Our Customers, and their employees on the same Account, may also send you notifications, messages and other updates regarding their or your use of the Services. You can control your communications and notifications settings from your Applicant Profile settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify eTribez at any time by sending an e-mail to support@etribez.com, changing your communications preferences in your Applicant Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
7. Data Security
We secure your Personal Data using industry-standard physical, procedural and technical measures.
In order to protect your Personal Data held with us, we are using industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
8. Data Subject Rights
Individuals have rights concerning their Personal Data. You may exercise your rights by contacting us or your Account Admin.
If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA)), to request access to, and rectification or erasure of your Personal Data held with eTribez, or to restrict or object to such Personal Data’s processing, or to port such Personal Data or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at privacy@etribez.com.
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
If you would like to make any requests or queries regarding Personal Data we process on our Customer’s behalf, please contact the Customer directly. For example, if you are an Applicant who wishes to access, correct, or delete data processed by eTribez on behalf of a Customer for a specific campaign or production you signed up for, please direct your request to the relevant Customer (who is the “Data Controller” of such data – see Section 9).
9. Data Controller/Processor
We are the Controller of our Visitors’ and Customers’ Personal Data; we are the Processor of any Personal Data contained in Customer Data, and of Applicant Data processed on behalf of our Customer.
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (under the CCPA the “business”), who determines the purposes and means of processing; and the “Data Processor” (under the CCPA the “service provider”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
eTribez is the “Data Controller” of its Visitors’ and Customers’ Personal Data. With respect to such data, we assume the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “Data Processor”.
If any of our Users or Applicants upload or submit Customer Data or other content to our Services which includes Personal Data (e.g., by submitting their colleagues’ or team members’ contact details to one of their Profiles), such data will only be processed by eTribez on behalf of our Customer, which is the Controller of the respective Account, along with all other Applicant Data and User processed on such Customer’s behalf.
In such instances, our Customer shall be deemed the “Data Controller” of such data, and eTribez will process such data on the Customer’s behalf, as its “Data Processor”, in accordance with its reasonable instructions, subject to our Terms, our Data Processing Agreement with such Customer (to the extent applicable) and other commercial agreements. eTribez’ Service Providers shall act as designated Sub-Processors in these instances. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
10. Additional Notices
We may update this policy from time to time; we are not responsible for other websites’ or services’ privacy practices; we have appointed a Data Protection Officer and have designated a Representative in the EU. Don’t hesitate to contact our DPO with any questions regarding privacy and data protection!
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.
Our Services is not generally designed to attract children under the age of 16: We do not knowingly collect Personal Data from children. If a Customer runs a campaign in which Users under 16 years of age can sign up, our platform supports the collection of appropriate parental consent, which is managed by the Customer. If you believe that we might have any such data without the appropriate parental consent, please contact us by e-mail at support@etribez.com, and we shall attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child.
DPO: eTribez has appointed Emilie Kuijt as our Data Protection Officer, for monitoring and advising on eTribez’ ongoing Privacy compliance and serving as a point of contact on Privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your Privacy, or if you wish to make a complaint about how your personal data is being processed by eTribez, you can contact support@etribez.com or our DPO at dpo@etribez.com.
EU Representative: Dr. Andreas Matzler (https://gdpr-rep.eu/) has been designated as eTribez’ representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Dr. Matzler may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please contact him through gdpr@etribez.com.
Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your Personal Data held with us, please contact eTribez’ support at support@etribez.com, or our Data Protection Officer at dpo@etribez.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
Effective Date: January 12, 2020