This Privacy Notice is effective as of June, 2019.
Feedvisor Ltd. (referred to in this Privacy Notice as “Feedvisor”, “we”, “us” and “our”) is based in Tel-Aviv, Israel. Our headquarters are located at 96 Spring Street, 7th Floor, New York, NY 10012.
This Feedvisor Privacy Notice (“Privacy Notice”) describes how Feedvisor collects, uses, shares, and retains personal data that you provide to us, or that we collect, when you use the website located at feedvisor.com and any website operated by Feedvisor or its affiliates or subsidiaries on which this Privacy Notice posted (together, the “Site”), and any services, widgets, content or applications made available on the Site (the Site and these services, content, widgets, and applications collectively constituting, the “Service”).
Please read this Privacy Notice carefully. If you disagree with anything in this Privacy Notice you must not use the Service. By using or continuing to use the Service or any services provided through the Service, you are accepting the terms, conditions and directions set forth in this Privacy Notice, as described below.
Occasionally we may, in our discretion, make changes to this Privacy Notice. When we make material changes to this Privacy Notice, we’ll provide you with notice as appropriate under the circumstances, for example, by displaying a prominent notice within the Service or by sending you an email. In some cases, we will notify you in advance, and where permissible, your continued use of the Service after the changes become effective will constitute your acceptance of the changes. Please therefore make sure you review any applicable changes carefully. If you do not agree to the revised Privacy Notice, you should stop using the Service.
Notice to residents of any member state of the European Union (“EU”), the European Economic Area (“EEA”), Switzerland, and the United Kingdom (collectively, “EEA Residents”). This Privacy Notice has a section dedicated to EEA Residents that provides additional information and opportunities to provide consent (where appropriate). Please refer to the Special Notice to Individuals in the European Economic Area, United Kingdom and Switzerland section of this Privacy Notice for more details about how Feedvisor’s Privacy Notice applies to EEA Residents.
1. What Data Does Feedvisor Collect & Why?
For purposes of this Privacy Notice, personal data means any information relating to an identified or identifiable person and includes identifiers such as a name, online identifiers such as an IP address, and email addresses. This is not an exhaustive list, but a few examples aimed at helping you understand what constitutes personal data. Non-personal user data is data that does not identify a specific person, such as information about a user’s computer operating system or browser, the number of users that visit the Site and the pages of the Site which are visited, as well as usage data as to certain features of the Service that are not connected to any particular user.
Where this Privacy Notice describes processing personal data, “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
The specific data Feedvisor collects, stores and processes depends on how you use the Service. Listed below is the personal data and non-personal user data that we collect, a description of the circumstances under which we collect the data, and why the personal data is collected.
- For Demonstration Requests, Event Registration, Webinar & Resource Downloads. If you request a demonstration, register for an event or webinar, or download resources provided through the Service, we collect: your first and last name, email address, telephone contact information, IP address, Amazon Store or Company that is considering using Feedvisor, the average monthly sales of the Amazon Store or Company you represent and whether the Amazon Store or Company competes for the Amazon “buy box” (a product detail page offered on Amazon where Amazon customers can begin the purchasing process and see multiple sellers offering the same product). We collect this personal and non-personal data you voluntarily provide so that we can determine the appropriate product demonstration offerings to discuss with you, tailor our events or webinars to better suit a particular prospective customer or group prospective customers, send you direct marketing related to your inquiries and/or requests, and generally provide more accurate and personalized information pursuant to the request you have made. Feedvisor deletes the personal data you submit when you request a demonstration, register for an event or webinar, or download resources provided through the Service within three years of the demonstration, event, webinar or delivery of resources.
- To Use Store Assessments. If you choose to use our store assessment tool, we collect: your first and last name, telephone contact information, average month sales categories for the Amazon Store or Company you represent, product promotion information, Fulfillment-by-Merchant (FBM) compared to Fulfillment-by-Amazon (FBA) ratio (if applicable), profit margin and technologies your Amazon Store or Company utilizes. We collect this personal and non-personal data you voluntarily provide so that we can provide a store assessment and help prospective customers consider the tools Feedvisor’s products may serve. Feedvisor deletes the personal data you submit to receive a store assessment within three years of using the store assessment tool.
- To Sign Up For Our Newsletter. If you sign up to receive our Newsletter, we will collect your email address in order to send you our Newsletter. If you no longer wish to receive the Newsletter, please follow the unsubscribe instructions at the bottom of the Newsletter.
- Website Activity Analytics Data. Feedvisor uses the third-party services and technologies to generate website activity analytics that help us better understand how visitors use our Site. For example, we use these technologies to learn which pages visitors spend the most time on, how our forms are used and what fields are difficult for users to complete to help us improve our Site and provide a better experience for visitors.
Information that is automatically reported by your browser each time you access the Service from your computer, tablet or smart phone, includes: browser type, operating system, the URL of the page that referred the user visiting our Site, pages visited on the Site, and the IP address. Feedvisor uses this information to administer the Site, analyze trends, and gather information about visitor movements to help us understand relevant and high areas of traffic on our Site, to help us diagnose potential problems with our server, investigate actual or potential security incidents, and ensure the Site is working properly.
- Customer Data to Use the Feedvisor Platform. If you or your company (the “Customer”) licenses the Feedvisor Platform to utilize and Feedvisor product or service (collectively, the “Feedvisor Platform”), the Customer must create a Master Account or User Account to use the Feedvisor Platform. Feedvisor collects, stores and otherwise processes your first and last name, title, company name, user name, password, e-mail address, telephone number, and postal address to allow us to:
- Facilitate the creation of and secure your Master and/or User Account on our network;
- Identify you as a user in our system;
- Eliminate the risk of fraudulent users or fraudulent activity on the Feedvisor Platform;
- Permit you to recover or change lost or forgotten passwords;
- Send you administrative notifications, such as security or support and maintenance advisories; and
- Respond to your inquiries or other requests.
While the Feedvisor Platform allows our Customers to provide us with access to certain end users’ personal data; however, our Platform immediately erases, and never stores, the following end users: first and last name, email address, and street address. We also immediately anonymize personal data containing the country, city, postal code and items purchased and stores and otherwise process this data on an anonymized and aggregated basis.In the course of using our Service, Feedvisor customers’ customer (“end users”) may submit or upload personal data to our Platform. This end user content is processed by Feedvisor on behalf of the customer, and our privacy practices will be governed by the contract we have in place with our customers. This Privacy Notice will not apply to any personal data contained in such customer content. In accordance with the terms of such contract, Feedvisor will process customer content for the purposes of providing the relevant Services and in accordance with our customer’s instructions. If you have any questions or concerns about how such information is handled, you should contact the person or entity who has contracted with Feedvisor to use the Service to process this information.
2. How Do We Share Your Information?
- Third-Party Processors and Service Providers. Feedvisor employs or engages other companies to perform business functions on behalf of Feedvisor (“Service Providers”), such as providing email services, operating and supporting the Service, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the information needed to perform these limited functions on our behalf but are prohibited by contract from using the information for other purposes, except as permitted by law or upon your consent. Our contracts with such persons are at least as protective as this Privacy Notice.
- Comply with Legal Obligation, Protect Rights, or Comply with Our Policies. To the extent permitted by law, we will disclose your information to government authorities or third parties if: (a) required to do so by law, or in response to a subpoena or court order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (c) we believe that you have abused the Service by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
- Third Party Partners. As permitted by applicable law or based on your consent, we may, from time to time, partner with a third-party for an event, webinar or resource you can download through the Service. In these circumstances, Feedvisor will share the personal data and other information you provide to us with the third-party partner to allow the third-party to offer products or services that may be of interest to you. If you would like us to stop providing your personal data and information to our third-party marketing partners for their own marketing purposes, you may opt-out by emailing us at firstname.lastname@example.org. Following our receipt of your election to opt-out, we will stop sharing your personal data and information with these third party marketing partners for their own marketing purposes within a reasonable time period. However, if we have shared your personal data or information with a third party marketing partner prior to this time, that third party will continue to have your information and may continue to send marketing communications to you. If you no longer want to receive marketing communications from the applicable third party, you will need to notify the applicable third party directly.
- To Protect You, Us or Others. We may share your personal data if we believe, in good faith, that such disclosure would protect your interests or rights, or the interests or rights of others, including Feedvisor and its personnel.
3. Where Is the Data Processed and Stored?
Personal data processed by Feedvisor is processed and stored by Feedvisor in the United States. Feedvisor uses reasonable physical, technical and administrative measures to safeguard all personal data it processes and prevent unauthorized access and disclosure of any personal data. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any personal data that we process. You acknowledge that Feedvisor processes your personal data at your own risk.
4. Transferring Personal Data from the EEA
If you Interact with us or provide your personal data to us, your personal data may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your personal data transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use this website, our resources, or the Services.
If you reside in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland, we transfer your personal data subject to appropriate safeguards as permitted under the applicable data protection laws. Specifically, when your personal data is transferred out of the EEA, UK or Switzerland, we have the required contractual provisions for transferring personal data in place with the third parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Standard Contractual Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.
Our Services are not directed to children under the age of 18. We do not knowingly collect any personal data from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, he or she should contact us at email@example.com. If we become aware that an individual under 18 has provided us with personal data, we will delete that information as soon as possible from our database(s) and files.
6. Rights of California Residents
Under California Civil Code Section 1798.83 (also known as the “Shine the Light” law), Feedvisor’s Customers and visitors or users of the Site who are residents of California may request certain information about Feedvisor’s disclosure of personal data during the prior calendar year to third parties. To make such a request, please contact us at firstname.lastname@example.org with the subject: “Shine the Light” or submitting your request by mail to: ATTN: Shine the Light: Raffy Wreschner, 96 Spring Street, 7th Floor, New York, NY 10012.
7. Do Not Track
The Site does not support “Do Not Track” requests. To determine whether any of the third-party services we use honor the “Do Not Track” requests, please read their privacy policies.
8. Data Retention
We will retain, use and otherwise process the personal data we collect for the purpose of creating a master or user account for as long as necessary to allow you to utilize the Feedvisor Platform, comply with our legal obligations, resolve disputes, and enforce our agreements.
As noted in this Privacy Notice, Feedvisor deletes the personal data you submit to receive a store assessment, get a demonstration or our services or products, register for an event or webinar, or download resources provided through the Services within three years after you provide such information.
In addition, any personal data that we receive from customers about end-users that includes: first and last name, email address, billing address, shipping address and postal number, and items purchased is immediately anonymized or deleted. Personal data containing countries, cities, postal codes, purchased items and store locations is anonymized, and first and last names, email addresses, and street addresses are deleted.
Unless otherwise noted in this Privacy Notice, the retention period for all other personal data is based on applicable legal and accounting requirements, the amount of personal data we have collected, its sensitivity and potential risks it involves. Once the retention period expires, we delete your personal data.
9. Privacy Rights For Individuals in the European Economic Area, United Kingdom and Switzerland
This portion of our Privacy Notice only applies to individuals located in the EEA, Switzerland, or the United Kingdom (collectively “EEA”) at the time of data collection. We may ask you to identify which country you are located in when you use the Service, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the EEA. If any terms in this section conflict with other terms contained in this Privacy Notice, the terms in this section shall apply to users in the EEA.
Our Relationship to You. Feedvisor is a data controller with regard to any personal data collected from individuals accessing or using its Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal data is processed. Any third parties that act as our service providers or are otherwise acting on our behalf are “data processors” that handle your personal data in accordance with our instructions.
Marketing. We will only contact individuals located in the EEA by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your personal data in this way, please click an unsubscribe link in your emails, or contact us at email@example.com. You can object to direct marketing at any time and free of charge.
Legal Basis for Processing Your Personal Data. We describe our legal basis for processing throughout this Privacy Notice. Below is a list of the purposes described in our Privacy Notice with the corresponding legal basis for processing. Generally, the legal basis on which we rely on to process your personal data includes: our legitimate interests balanced against any potential impact on you and your rights; your consent to the processing; our legal obligations, and the necessity to protect your vital interests as described in the table below.
|Section & Purpose of Processing||Legal Basis for Processing|
|Section 1(a): For Demonstration Requests, Event Registration, Webinar & Resource Downloads
Section 1(b): To Use Store Assessments
Section 1(c): To Sign Up for Blog Newsletter
Section 2(a): Third-Party Processors and Service Providers
Section 2(c): Business Transfers; Bankruptcy
|Based on our legitimate interests. When we process your personal data for our legitimate business interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.|
|Section 1(e): Customers Data to Use Feedvisor Platform||Based on contract.|
|Section 1(d): Website Activity Analytics
Section 1(f): To Use the Drift Chatbot
Section 2(d): Third Party Partners
|Based on your consent.|
|Section 2(b): Comply with Legal Obligations, Protect Rights, or Comply with Our Policies||Based on our legal obligations.|
|Section 2(e): To Protect You, Us, or Others||To protect your vital interests.|
Data Subject Rights. This portion of our Privacy Notice advises EEA residents of the applicable GDPR rights (often called “data subject rights”) and how to effectuate these rights by communicating with us. We provide you with the rights described below when you use our Service. We may limit your individual rights requests in the following ways: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; and (d) where the request is frivolous or burdensome. Please note, we may seek to verify your identity when we receive an individual rights request from you to ensure the security of your personal data.
- Right of Access. This Privacy Notice advises you as to the details of the personal data Feedvisor is processing. If you need additional confirmation concerning the personal data Feedvisor is processing, you may request confirmation by sending an email to firstname.lastname@example.org with Right of Access in the subject line. Upon your request, we will provide you with a copy of your personal data in our files without undue delay and free of charge, unless we are permitted by law to charge a fee.
- Right to Withdraw Your Consent. If we ever asked for your consent to process your personal data, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
- Right to Rectification (or “Correction”). If you believe Feedvisor has inaccurate or incomplete personal data, you may request rectification. We may provide you with the ability to update some or all of your personal data directly via the Service.
- Right to Erasure (or the “Right to be Forgotten”). Upon your request, we will erase any of your personal data in our files that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. You may request erasure/deletion by sending an email to email@example.com with “Right To Be Forgotten” in the subject line.
- Right to Restriction. You have the right to restrict our processing of your personal data where one of the following conditions applies:
- You contest the accuracy of your personal data that we processed. If you restrict processing based on this condition, you may experience an interruption of some or all of the Service during the period necessary for us to verify the accuracy of your personal data;
- The processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead;
- We no longer need your personal data for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
- You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
During the time which restriction of processing applies, we will only process your restricted personal data with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted. You may request restriction of processing by sending an email to firstname.lastname@example.org with Restriction of Processing in the subject line.
- Right to Object. You may object to our processing at any time and as permitted by applicable law if we process your personal data on the legal basis of: consent; contract; or legitimate interests. We may continue to process your personal data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law. You may object to Feedvisor’s processing activities by sending an email to email@example.com with Data Subject Objects to Processing in the subject line.
- Right to Data Portability. If we process your personal data based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal data in a structured, commonly used and machine-readable format, and to have us transfer your personal data directly to another “controller,” where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. Your right to data portability only applies to personal data provided by you to us. You may make a data portability request to Feedvisor by sending an email to firstname.lastname@example.org with Data Portability in the subject line.
- Notification to Third Parties. When we fulfill your individual rights requests for correct (or rectification), erasure or restriction of processing, we will notify third parties also handling the relevant personal data unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.
- Automated Individual Decision-Making, Including Profiling. You have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.
- Right to Lodge Complaints. If you believe that we have infringed or violated your privacy rights under applicable law or this Policy, please contact us at email@example.com so that we can work with you to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.
How to Contact Us
We take your privacy concerns seriously. If you have any questions or concerns about this Privacy Notice, please contact us by sending an email to firstname.lastname@example.org.