Case Study

Privacy Policy

1. Introduction 

1.1.This Privacy Policy (together with the Terms of Use (“Terms of Use“) and any other documents  referred to on it, hereinafter the “Policy“) informs you about the details of the processing of  personal data you transmit, upload or otherwise make available during your use of the Website (“You” or “User” and “Website“, respectively) or which You provide Us through such use. 

1.2.In this Policy, “Leap 4” or “We” or “Us” will mean Gefen Yuval Digital Ltd. If You are a user located  in the European Economic Area (“EEA”) or if you intend to transmit or upload data concerning  EEA residents, please carefully note the information in this Policy on your rights under the  2016/679 EU General Data Protection Regulation (“GDPR”).  

1.3. Leap 4 recognizes the importance of keeping Your information secure and will ensure that the  collection, use and sharing of Personal Information will be conducted in accordance with the  terms of this Policy.  

1.4.This Policy may be updated from time to time if and when our privacy practice changes; each  version will apply to information collected while it was in place. You are advised to consult this  Privacy Policy regularly for any changes. 

1.5.In this Policy, anything that appears in a masculine form shall also mean the feminine form and  vice versa. 

1.6.All Capitalized terms used but not defined herein shall have the meanings given to such terms in  the Terms of Use.  

2. Information Collection and Use 

2.1. Leap 4 may collect, receive, retain and process the following information (“Personal  Information“):  

2.1.1. Information that You provide Us when You request a demo in the Website, which may  include your first and last name, address, email address, phone number, date of birth,  etc.; 

2.1.2. Device and app information–your device’s type and model, system language, the device’s  operating system (such as Android or iOS), carrier name, browsers installed on the device  (such as Chrome or Safari), IP address, and identifiers assigned to your device, such as its  iOS Identifier for Advertising (IDFA), Android Advertising ID, or other types of unique  device identifiers (a number uniquely allocated to your device by your device  manufacturer); 

2.1.3. Technical information, such as your computer’s IP address, operating system, type of  browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and  activities on the Website, the period of time the User visited the Services and related  time stamps the website from which you were linked to ours, the time and date of your  visit, your searching history, the websites to which you were linked through the Website,  and your activities in the Website; 

2.1.4. Information about the use of the Website, such as how often users visit the Website,  what pages they visit when they do so, and what other websites they used prior to  coming to the Website (including by collection the IP address assigned to you on the date  you visit the Website); 

2.1.5. Ad information–the online ads and personalized content we have served (or attempted  to serve) to You. It includes how many times an ad has been served to you, what page  the ad appeared on, whether you viewed, clicked on or otherwise interacted with the ad,  ad engagement history and whether you visited the advertiser’s website, downloaded an 

app or purchased the product or service advertised. 

2.1.6. In addition, certain advertisers may also collect the precise location of your device (using  GPS signals, device sensors, Wi-Fi access points, Bluetooth signals, Beacons signals and  cell tower ids that can be used to derive or estimate precise location, or other geo location data), when location services have been enabled by the End-User (you typically  have to choose to turn on device-based location services). 

2.2. Leap 4 main objective in storing and processing Your Personal Information, as described in this  Privacy Policy, is to provide You with access to our Website and to allow you to use our services  and to perform our obligations to You. We may also process some of Your information to support  and fulfil our legitimate business interests, such as self-study and internal statistics, and to allow  Us to comply with legal and contractual obligations or defense against legal claims may use this  information mainly to fulfill our contract with You. 

2.3.In addition, Leap 4 may use the Personal Information collected in the following manners (We will  treat all the aforementioned and the following as “Purpose“):  

2.3.1. Recognize you when you return to use the Website. 

2.3.2. For that reason, We also use cookies. Cookies are small text files that You load onto Your  device when You use our Website and store the Personal Information. We use our own  cookies in order to identify and recognize You when You return to use the Website and  provide You with an easier automated login.  

2.3.3. Estimate amount of users logging to the Website and usage pattern. 

2.3.4. To conduct research and for further development of Leap 4 services in order to provide  You with a better, more intuitive experience, including by way of development of new  features. 

2.3.5. Monitor the use of the Website and administrate the Website, for Leap 4 technical  administration including for security reasons. 

2.3.6. allow our Publishers to promote advertising, apps and content in their Properties, and to  allow advertisers to bid on Publishers’ inventory. 

2.3.7. enable our partners to infer interests and serve ads and personalized content to End Users based on their behavior, app activity and inferred interests. 

2.3.8. measure ad performance, report to advertisers when and how End-Users have viewed or  clicked on their ads, or visited their website, and to report to Publishers when and how  ads were shown on their properties and were clicked on. 

2.3.9. allow our Publishers to analyze their applications (for this purpose, we use aggregated  and anonymous benchmark data) and prevent End-Users from seeing the same ad too  many times. 

2.3.10. identify invalid or incentivized clicks (or ad queries) and protect us and our partners from  fraudulent behavior. 

2.3.11. Enforce our policies, resolve disputes and communicate with you. 

2.4. Leap 4 stores the Personal Information while you are subscribing to the Website and use our  services. Leap 4 may also store said information for a period of time after you no longer use the  Website if the information is necessary for the purposes for which it was collected or to satisfy  legal requirements. These purposes typically include business, legal, or tax purposes.  

2.5.All information provided by you or collected by Leap 4 is stored on Leap 4′ secure servers.  Unfortunately, the transmission of information via the internet is not completely secure.  Although Leap 4 will make reasonable commercial effort to protect your personal data, Leap 4

cannot guarantee the complete security of your data transmitted to the Website and therefore  any transmission is at your own risk. Once Leap 4 has received your information, Leap 4 will use  strict procedures and security features to try to prevent unauthorized access. 

3. Disclosure of information 

3.1. Leap 4 may disclose your Personal Information to third parties or governmental authority, under  the following obligations: Leap 4 is engaged with certain selected third parties which provide  services to Leap 4, including, cellular or communication networks, hosting, database storage and  maintenance, billing and ecommerce AWS, Heroku, and process services (such as Google 

Analytics and Firebase. In addition, and in order to provide You with the Services, Leap 4 may be  engaged with third parties who provide services similar that provided by the Leap 4 to You. 

3.2. Leap 4 may share Your information with these third parties, but only to the extent necessary for  the Purpose unless otherwise permitted by law, and only pursuant to binding contractual  obligations requiring such third parties to maintain the privacy and security of Your information. 

3.3.It is hereby clarified that some of the Personal Information collected and processed by these third  parties is collected directly by them (and not transferred by us). We provide these third parties  with access to the Website and Services and enable them to collect and use the Personal  Information in order to provide You with excellent Services. In case You object to the process of  any of these third parties of Your Personal Information, You can contact Us and ask Us to stop  granting them with access to Your Personal Information. Please note that in such case some or  all of the Services may not be available to You. 

3.4.When We believe in good faith that disclosure is necessary to protect our rights, protect Your  safety or the safety of others, investigate fraud, or respond to a government request (including  court order, search warrant). 

3.5. Leap 4 may disclose the Personal Information in the event where Leap 4 shall transfer in any way  the operation of the Services to any third party and should it merged with another entity or  merge the operations of the Services with the activity of a third party, provided that this  corporation will assume the user to this Privacy Policy. 

3.6. Leap 4 may disclose the Personal Information where You are performing any act in the Services  which constitutes a violation of any law or the Terms of Use. 

4. Security 

The security of Your Personal Information is important to us. Leap 4 employs administrative,  contractual, physical and electronic measures and security safeguards designed to protect Your  information from unauthorized access. To protect the confidentiality of Personal Information, You  must keep your password confidential and not disclose it to any other person. If other people have  access to Your email, they may be able to obtain access to Your password and obtain personal  information about You, or change information about Your user. However, Leap 4 cannot warrant the  security of any information that You provide. There is no guarantee that data may not be accessed,  disclosed, altered, or destroyed by breach of any of Leap 4 physical, technical, or managerial  safeguards. If You have any questions about the security of the Services, You can contact Us as using  the Contact Info detailed below. 

5. Your Rights with respect to the Personal Information 

5.1. Leap 4 offers You to control and manage the Personal Information Leap 4 has about You. You are  entitled to ask Leap 4 to:  

Withdraw the consent – You may, at any time, withdraw your consent and no longer permit  Leap 4 to use and keep Your Personal Information. Please note that by doing so, Your  experience of the Services may be affected and You may not be able to use all or part of the  Services that Leap 4 offers.

Delete Data – You can ask Leap 4 to erase or delete all or some of the Personal Information  (e.g., if it is no longer necessary to provide the Services). 

Change or Correct Data – You can ask Leap 4 to edit some of the Personal Information by asking  Leap 4 to change, update or fix Your Personal Information in certain cases, particularly if it is  inaccurate. 

Object to, or Limit or Restrict, Use of Personal Information – You can ask Leap 4 to stop using  all or some of its Personal Information (e.g., if Leap 4 has no legal right to keep using it) or to  limit Leap 4 use of it (e.g., if the Personal Information is inaccurate or unlawfully held). 

Further, you have the right, for reasons arising from your particular situation, to object at any time  to the processing of your personal data, which is processed on the basis our legitimate interests; this  also applies to any profiling based on this processing. If you object, we will no longer process your  personal data in the future unless we can prove compelling grounds for the processing that outweigh  your interests, rights and freedoms or the processing serves to assert, exercise, or defend legal  claims. 

You also have the right to object at any point in time to the processing of your data for direct  marketing purposes (i.e. receiving newsletters or other direct marketing communications). If you  exercise your right to objection, we will no longer use your Personal Information for sending you any  marketing communications. 

Right to Access and/or Take Your Data – You can ask Leap 4 for a copy of Personal Information  and can ask for a copy of Personal Information You provided in machine readable form. 

5.2.In case any of the foregoing actions is not available through Your account, You can contact Leap  4 at the Contact Info (as detailed below) and ask Us to perform it. You acknowledge that by asking  Leap 4 to not store or process the Personal Information or by performing any of the foregoing  actions on its own, You may prevent Us from providing You with the Services, and be prevented  from using all or part of the Services. You hereby waive any claim or demand You might have  against Leap 4 in this matter. 

5.3.If You believe that the process of the Personal Information is not complying with the law  applicable to You or Leap 4’s response have not satisfied You, You may lodge a complaint to the  relevant supervisory authority. 

6. Lawful Bases for Processing 

6.1. Leap 4 has lawful bases to collect, use and share data about each user of the Website. The  primary lawful basis is based on the engagement of You with Us, in order for Leap 4 to provide  You with the Services and to be able to contact You from time to time (where processing is  necessary for the performance of a contract with You). 

6.2.In addition, lawful bases include consent (where You have given consent), our legitimate interests  and may also be a legal obligation to which We are subject.  

6.3.In case there is more than one lawful bases for processing Personal Information, We may rely on  any of the lawful bases even if the lawful basis is not explicitly stated in this Policy. 

6.4.Where Leap 4 rely on Your consent to process Personal Information, You have the right to  withdraw or decline consent at any time and where Leap 4 rely on legitimate interests, You have  the right to object to the processing of Your Personal Information for reasons arising from Your  particular situation. If You have any questions about the lawful bases upon which Leap 4 collects  and use the Personal Information, please contact Us through the Contact Info.  

6.5.At any time, You can withdraw the consent You have provided Us by contacting Us using the  contact information detailed below.

7. Links to Other Sites  

The Website may, from time to time, provide you with links to and from sites of advertisers and  affiliates. Those links can be published on the Website by you, Leap 4 or third parties. These third  party sites may collect information about you if you click on a link. The fact that Leap 4 links to a  website does not constitute as an endorsement, authorization or representation of Leap 4 affiliation  with that third party. Leap 4 do not exercise control over third party Sites. These other websites may  place their own cookies or other files on your computer, collect data or solicit personally identifiable  information from you. If you follow a link to any of these websites, you do so at your own risk, these  sites have their own privacy policies and you are advised to review these policies before providing  any personal data to these websites. You waive any claim against Leap 4 for any responsibility or  liability for these policies. 

8. Policy towards Children  

The Service is not directed to children. By using the Website and/or the Service and approving the  Terms of Use and this Policy, You also approve that You understand that the services provided are  not intended for children under the age of 18 and addressed solely to a natural person who is at  least 18 years old. We do not use the Services to knowingly solicit data from children under the age  of 18. If a parent or guardian becomes aware that his or her child has provided Us with information  without their consent, he or she should contact Us at the Contact Info provided below. We will delete  such information from our files within a reasonable time. 

9. Questions or Concerns 

If You have any questions or concerns about this Policy or would like to contact Us for any reason,  You can e-mail Us at (the “Contact Info“).

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