EFFECTIVE DATE: MAY 18, 2017

1. INTRODUCTION

   1. PURPOSE OF POLICY. Mybestclick Ltd. (“Mybestclick”) is committed to respecting the privacy rights of its customers, visitors, and other users of the website located at www.mybestclick.net (the “Site”) or of any software or services provided by Mybestclick (collectively, the “Service”). Mybestclick created this Privacy Policy (this “Policy”) to give you confidence as you visit and use the Site and/or Services, to demonstrate our commitment to fair information practices and the protection of privacy and to inform you about our practices relating to the collection, use and disclosure of your Personal Information (as defined below) that may be acquired or provided through your access to or use of the Site or Services. This Policy is only applicable to the Site and Services, and not to any other third party websites or services that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy. This Policy also explains how you can contact us if you have a question about, or want to remove any Personal Information about you that Mybestclick may be holding.

   2. NOTICE CONCERNING CHILDREN. The Site is a “general audience website”, and Mybestclick does not knowingly collect or maintain Personal Information from persons under 13 years of age and does not direct the Site, the Services or any of our content specifically at children under 13 years of age. If you are under 13 years of age, then you may not use or access the Site or the Services at any time or in any manner. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a user of the Site or Services is under age 13 or if we learn or have reason to suspect that Personal Information of persons under age 13 has been collected on the Site or through the Services without verifiable parental consent, we will take steps to promptly delete any such Personal Information.

2. INFORMATION COLLECTION PRACTICES

   1. INFORMATION COLLECTED BY Mybestclick. In operating the Site and providing the Services, Mybestclick may collect certain information, including without limitation the following:

      1. PERSONAL INFORMATION. When you sign up for an account at the Site or register for any Services, Mybestclick may ask you for personally identifiable information including but not limited to your name, mailing address, phone number, e-mail address, contact preferences and credit card or other billing information (“Personal Information”).

      2. AUTOMATICALLY COLLECTED INFORMATION. Our servers automatically recognize information that your browser sends whenever you visit a website, which may include information such as the domain names and Internet Protocol (IP) addresses of visitors to the Site, as well as the browser type and the date and time of the browser’s access to the Site. No Personal Information about you is revealed in this process and we generally treat information collected by such process as non-Personal Information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Information by local law, we treat these identifiers as Personal Information. The Site may also gather anonymous “traffic data” that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer.

      3. COOKIES. From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to the Site. Cookies help us to understand user behavior, and learn which areas of the Site are useful and which areas need improvement. We do not set any Personal Information in cookies, nor do we employ any data capture mechanisms on the Site other than cookies. We treat information collected by cookies as non-Personal Information. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this function, your experience at the Site may be diminished and some features may not work as they were intended. You can also delete cookies that have already been set. You may wish to visit http://www.allaboutcookies.org which contains comprehensive information on how to do this on a wide variety of desktop browsers.

      4. COMMUNICATIONS. When you send email or other communications to Mybestclick, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

3. USE AND SHARING OF INFORMATION

   1. PERSONAL INFORMATION. We will not sell, distribute or rent your Personal Information with any third parties without your consent, except to our trusted business partners for the purpose of providing you with, and operating and maintaining, the Site and Services, to comply with applicable law or as otherwise specified herein. We may use your Personal Information and/or share it with certain third parties to activate and maintain your account, verify your identity, check your qualifications, or follow up or resolve with transactions or queries initiated on the Site, including, but not limited to, processing your credit card payment or other payment, if applicable. We may also use your contact information to inform you of any changes to the Site or Services, respond to your questions, inquiries, comments and instructions, take good faith steps to enforce the terms of use with respect to the Site and Services, maintain the security and integrity of the Site and Services or our systems, or to send you additional information about Mybestclick.

   2. ANONYMOUS INFORMATION. We use anonymous information to analyze our Site traffic, but we do not examine this information for Personal Information. In addition, we may (subject to “AUTOMATICALLY COLLECTED INFORMATION” above) use anonymous IP addresses to help diagnose problems with our servers, to administer our Site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.

   3. USE OF COOKIES. We may use cookies to deliver content specific to your interests, to save your password so you don’t have to re-enter it each time you visit our site, or for other purposes.

   4. LEGAL DISCLOSURE OF PERSONAL INFORMATION. Without limitation to the foregoing, we may disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce the Terms of Use Agreement, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Mybestclick, its users or the pubic as required or permitted by law.

   5. SALE OF INFORMATION. In order to accommodate changes in our business, we may sell, buy or otherwise transfer portions of our company or other companies or assets, including the information collected through this Site. In the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or substantially all of the assets of Mybestclick, user information (including Personal Information) will be one of the assets transferred to the transferee.

   1. OPTING-OUT AND OPTING-IN. Mybestclick may use non-Personal Information that we collect in mobile apps to tailor advertising to you in other mobile apps and sites. You can opt out of cross-app and cross-site use of non-Personal Information:

      • For iOS devices, you can opt out of cross-app advertising by updating to iOS 6.0 or higher and enabling "Limit Ad Tracking" setting. On iOS 6 this setting is located in Settings -> General -> About -> Advertising menu. On iOS 7, it is located in Settings -> Privacy -> Advertising menu.
      • For Android devices, please email us your device ID at contacts@mybestclick.net and mention "OPT OUT" in the subject line. To find your device ID, go to Settings -> About Phone -> Status. To opt-out of our mailing list, please click unsubscribe in the body of the email communication. You are able to opt-in at any time. We do not collect IMEI or MEID information.
      • You can also delete cookies that have already been set. You may wish to visit http://www.allaboutcookies.org which contains comprehensive information on how to do this on a wide variety of desktop browsers.

   2. REMOVAL OF INFORMATION. When you request us to delete your account for the Services, your data will be permanently expunged from our primary production servers and further access to your account will not be possible. However, portions of your data may remain on our production servers indefinitely. Your data may also remain on a backup server or media. Mybestclick keeps these backups to ensure our continued ability to provide the Services to you in the event of malfunction or damage to our primary production servers. We also reserve the right to use any aggregated or anonymous data derived from or incorporating your personal information.

   3. RETENTION OF INFORMATION. Mybestclick will retain your Personal Information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) remains valid after termination of Mybestclick’s relationship with you.

4. SECURITY

   Mybestclick has implemented and maintains administrative, technical and physical security measures to help prevent unauthorized access, disclosure, loss, theft, misuse, destruction and alteration of your Personal Information, but we cannot guarantee that such measures will prevent any unauthorized access, disclosure, loss, theft, misuse, destruction or alteration of your Personal Information. Mybestclick will notify you of any suspected or confirmed unauthorized access, disclosure, loss, theft, misuse, destruction or alteration of your Personal Information to the extent required by and in accordance with applicable state and federal laws. We may attempt to notify you so that you can take appropriate protective steps, or we may post a notice on the Site if a security breach occurs.

5. WEBSITE AREAS BEYOND Mybestclick’S CONTROL

   1. PUBLIC FORUMS. The Site may include interactive forums such as bulletin boards and blogs. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your Personal Information. Mybestclick will not be liable for any disclosure of your Personal Information or other information as a result of your use of any such public forums, that you display publicly or that becomes publicly known as a result of your actions.

   2. THIRD PARTY WEBSITES. The Site may contain links to other websites. If you choose to visit any other websites other than the Site, we will not be responsible for the privacy practices or content of those other websites, and you shall bear all risk of access to such websites. It is solely your responsibility to review the privacy and usage policies at those websites and confirm that you understand and agree with their policies.

6. CONTACT INFORMATION AND POLICY UPDATES

   1. CONTACTING US. If you have any questions about this Policy, or our practices related to this Site, please feel to contact us at contacts@mybestclick.net.

   2. UPDATES AND CHANGES. We reserve the right, at any time and at our sole discretion, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site, provided that if you do not wish to accept any such changes, you will be given the option to opt-out of the use of the Site or the receipt of any Services in accordance with the Terms of Use Agreement. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms. You agree that, by continuing to use or access the Site or Services following any update or change, you shall be bound by any such update or change.