PRIVACY and COOKIE POLICY

1. Definitions

   "Personal Information" is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

   "process" or "processing" means any operation which is performed upon Personal Information, whether or not by automatic 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.

2. Scope

   This Privacy and Cookie Policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any Personal information we collect about you, or that you provide to us, will be processed by us. It applies to the Site and all related sites, applications, and services provided by Company (the "Services"), regardless of how you access or use them.

   Please note: you are not obligated by law to provide us with any Personal Information. However, without providing it you will not be able to receive the Services, which require registration and provision of details as stated. You hereby acknowledge and agree that you are providing us with Personal Information at your own free will, for the purposes described in this Policy, and that we may retain such Personal Information in accordance with this Policy and any applicable laws and regulations.

3. Which information we may collect on our Users and how it is collected?

   There are several types of data and personal information we may collect:

   Information you voluntarily provide us: Personal Information which is provided voluntarily by the User: (i) during registration to the Service through the Site and/or any kind of social network (such as Facebook, Twitter, Linkedin, etc.) which is using Single Sign-On mechanisms (as shall be further explained below); or (ii) when you communicate with us in any way, or ask for our support, you may voluntarily give us information that we collect.

   Registration to the Service. The registration to our Service is done either (i) through the Site, by logging on to the Site or performing a registration to the Service specifically; or, (ii) registration through social network provided you hold an active account on such Network (see below registration through Facebook).

   Information collected during the registration process to the Service through the Site. During registration we shall collect your full name, email address, address, job name, job title, company name, country, state, city, postal code.

   Information collected during the registration process from social networks, such as Facebook, Twitter, LinkedIn: When you connect to the Service through social networks for the first time, you will be asked to permit that network to share with the Service the following information about you: your social provider name, your profile URL, your User Id, your Display Name.

   Information collected during the registration process to the newsletter service: During registration we shall collect your full name, email address, address, job name, job title, company name, country, state, city, postal code.

   In addition, you may decide to provide us additional information when you communicate with us by phone, e-mail, or otherwise, or once you enter information on our Site. We may monitor and record correspondence with you, including via e-mails, live chats, or other communications between you and our Customer Service representatives.

   Information we collect automatically: We collect Personal Information automatically while you access or use the Service. The information includes technical information and behavioural information associated with your use of the Site or Services in any one or more of the following ways:

   • When you access and use the Services, we may collect information about your visit to our Site, your usage of the Services, your clicks on certain content and campaigns, and your web browsing. That information may include certain "traffic data" on Company's server logs from your browser, such as your IP address, your operating system, language settings, browser ID, location data, browser type, domain names, demographic information, such as your ZIP code, age, gender, preferences, interests and favourites, and other information about how you interacted with our Site or other websites. We may collect this information as a part of log files as well as through the use of cookies, log files and other tracking technologies on the Services, to collect, store and analyse certain information.
   • Behavioural information includes the activities of the user on the Service(e.g. which products/categories/sources is he/she interested in, etc.), User's behaviour on our Service/application (g. items clicked on, last login date, etc.) and any similar behavioural information.
   • We may use third party services, such as Google Analytics, to collect and process such data in order to analyse the traffic to the Website. To check how you can exclude cookies and other traffic data, please refer to clause 17.

4. Anonymous and Aggregated Information:

   We may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information. We may share this information with third parties for their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

5. How can you access, verify, modify or delete your Personal Information?

   You can access your profile and Personal Information via our web interface at "https://empty.caboodleai.net" You have the possibility to:

   • change your identification data (your e-mail or your password)
   • change your personal data
   • change your subscriptions
   • or even completely unsubscribe from the service. In this case, all your data will be erased from our database after 30 days.

6. Registration on the Site

   When you enter our Site, click on the "Create your news feed". You will then be required to complete the registration process, through the Site or a social network by providing us some of your Personal Information (as specified above). As part of the registration on the Site, you may create a profile compatible with your personal interests while choosing the categories, topics and sources that you are interested in receiving news feeds and updates about.

7. Legal basis for processing

   We will only process your Personal Information:

   • To perform our obligations towards you or based on your consent (where you have given consent). Please note that where we rely on your consent, you may withdraw your consent at any time, by contacting us at: info@CaboodleAI.com and you may unsubscribe from our newsletter services by following the unsubscribe instructions included in every newsletter email we send.
   • where we have a legitimate interest to process data, namely the proper administration of our business and the protection and assertion of our legal rights, subject to such processing not overriding your own rights and freedoms in objecting to such processing. Where we rely on legitimate interests, you have the right to object as specified under clause 11

8. What are the purposes of the collection of information?

   (a)Non-personal aggregated Information is collected in order to:

   • Enhance the User's experience on the Service.
   • Troubleshoot errors and bugs.
   • Learn about the preferences of Users and general trends on the Service (e.g. understand which topics and/or content sources are more popular than others).
   • Research, internal analysis, analytics.

   (b)Personal Information is collected in order to:

   • Enable the overall operation of the Service.
   • Personalise your experience on the Service, per your request, and provide you with certain information and services tailored for your interests.
   • Allow us to contact you with newsletter and direct marketing proposals and tailored information regarding new products, offers, services, etc. If you no longer wish to receive these communications, you can unsubscribe by following the instructions contained in the emails you receive or on our website by removing your account from "My profile" page "https://empty.caboodleai.net"
   • Identify you when conducting customer service operations (such as providing feedback, support etc.).
   • Allow you to register for special offers, contests or premium services, as may be.
   • Investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

9. Sharing Personal Information with Third Parties

   We share Personal Information only in the following cases:

   • With our trusted service providers that may be located in countries outside of your jurisdiction.
   • to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
   • to enforce this Privacy Policy or the Terms of Use, including investigation of potential violations thereof;
   • to detect, prevent, or otherwise address fraud, security or technical issues;
   • to respond to claims that any content published on the Service violates any right of a third-party.
   • to respond to claims that unauthorized information (e.g. phone number, name, etc.) of a third-party has been posted on the Service;
   • to protect the rights, property, or personal safety of the Company, the Users or the general public;
   • when Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, subject to restrictions similar to those contained herein or as otherwise be required by applicable laws and regulations;
   • pursuant to your approval, in order to provide you with certain services you have requested from Company;
   • to let our partners and affiliates (including advertisers) to serve you with commercials and offers, including by providing our partners with information of Users' preferences and interests in their products and/or services;

10. Data Transfers.

    We operate in the United Kingdom, the European Union and the United States so your information may be transferred to, stored, or processed and stored in those jurisdictions. We also have operations and service providers throughout the world, such as our mail service providers, our hosting and support service providers who operate in the United Kingdom, European Union, Israel, Ukraine and the USA.

    As such, we may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. While the data protection and privacy laws of the United States and other countries might not be as comprehensive as those in your country, we take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

    If you do not consent to this transfer, storing, or processing of your Personal Information at countries outside the European Union, please email: info@CaboodleAI.com indicating your wishes.

11. Your Rights as a Data Subject.

    As a data subject you have the following rights which can be exercised by contacting us at info@CaboodleAI.com:

    • The right to confirmation and access

      You have the right to access to your Personal Information obtained by us. Please refer to clause 5 for more information.

    • The right to rectification

      You have the right to have any inaccurate Personal Information about you rectified and to have any incomplete Personal Information about you completed.

    • The right to erasure

      You have the general right to request the erasure of your Personal Information

    • The right to restrict processing

      You have the right to restrict the processing of your Personal Information under certain circumstances.

    • The right to object to processing

      You have the right to object to processing of your Personal Information under certain circumstances.

    • The right to withdraw consent.

      Where the legal basis for processing your Personal Information is your consent, you have the right to withdraw that consent at any time, including in respect of direct marketing.

    • The right to data portability

      In certain circumstances, you have the right to receive your Personal Information from us in a structured, commonly used and machine-readable format, and also the right to transmit your Personal Information from us to another data controller without any hindrance from us where this is technically feasible.

    • The right to complain to a supervisory authority

      If you consider that our processing of your Personal Information infringes data protection laws applicable to you, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

12. Direct Marketing

    If you no longer wish to receive newsletters or other promotional emails, you may opt out of receiving these communications. You may opt out of promotional emails by following the unsubscribe link placed in the footer of the promotional email or you can simply contact info@CaboodleAI.com and ask to be unsubscribed from newsletters and promotional emails.

13. Information about minors

    Our Services are intended for professionals in the industry. We do not knowingly collect any personal information from anyone under 13 years of age. If we obtain knowledge that a User is under the age of 13, we will take steps to cancel his/her registration.

14. Data Retention

    The time periods for which we retain your Personal Information depend on the purposes for which we use it. We may retain information about you in our databases for as long as your account is active or as needed to provide you Services and in accordance with applicable laws. Our retention and use of your information will be as necessary to provide you with the Services, to comply with our legal obligations, resolve disputes, and enforce our agreements.

    If you requested to close your account with us, we will delete your Personal Information from our records within 30 days, except for special circumstances where we may extend this period as long as it is reasonably necessary in order to respond to any legal issues or to comply with our legal obligations (including law enforcement requests). In addition, we may need to retain your email address beyond the end of our relationship with you in order to fulfil your request to "unsubscribe" from further messages from us. We may also retain de-personalized information after your account has been closed.

15. Advertising

    We may publish on the Site and/or Service advertisements through third party advertisers. These advertisers are carefully selected to provide information about products and services that we think may be of interest to our Users. Note that if you click on any of these advertisements, these advertisers may use cookies and other web-tracking technologies to collect Non-Personal and/or Personal Information about you. We recommend that you review the terms of use and privacy policy for any advertiser with which you are willing to interact before doing so. Their privacy policy, not ours, will apply to any of those interactions.

16. Modifications or Deletion of Personal Information

    If for any reason you wish to modify or delete your Personal Information provided to the Service, please notify us at:info@CaboodleAI.com and we will amend your Personal Information within reasonable time upon your request. Deleing your Personal Information from our databases shall be done after your request to un-list yourself from our databases and cease the Service at:info@CaboodleAI.com

17. Cookies & Local Storage

    When you access or use the Service, Company may use industry-wide technologies such as "cookies" and Flash (or similar technologies), which stores certain information on your computer ("Local Storage") and which will allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless. We may also use the data collected via cookies to tailor advertisements to you and to track the popularity of our website. Our use of cookies and other technologies may allow us and third parties to collect information about your browsing activities over time and across different websites following your use of our services.

    The cookies used by the Service are created per session, does not include any information about you, other than your name as well as your session key and are removed as your session ends (usually after 24 hours).

    We may use the following cookies:

    1. Essential cookies: These cookies are necessary to allow you access and move around our Website and use all its features. Without these cookies, you would not be able to access our Website and/or to use certain important features.
    2. Visitor Cookies: These cookies are part of our security mechanism and are used to identify visitors (visitor representing a specific computer) of the Website.
    3. Functional Cookies: These cookies may store your browser name, the type of computer and technical information about your means of connection to this website, such as the operating system and the Internet Service Providers utilized and other similar information. This information is used to technically facilitate the navigation and use of this website. In addition, functional cookies may be used to store personal settings, such as language, or to remember your information for next visits if so requested.
    4. Analytics Cookies: These cookies are placed by Google Analytics (including Google Tag Manager) to measure the number of visits and the parts of the website that are the most popular among our website visitors as well as for benchmarking purposes. This information is used to provide aggregated and statistical information on the use of this Website and is used to improve the contents of this Website to enhance your user experience.
    5. Advertising Cookies: These third party cookies, such as Google Adwords, help ensure that our advertisements are as relevant to you as possible. These cookies track and record information (including by Google) regarding your browsing habits and activity, and use this information to enable us to show you relevant/personalized marketing content across the Internet. Using these cookies, our third party vendors may collect personally identifiable information (for instance when information collected by such cookies is associated with your Google Account) and use this to display our targeted advertising to you. For example, some advertising cookies help select advertisements that are based on your interests. You can opt out of Google's use of the abovementioned cookies by visiting Google's Ads Settings: https://adssettings.google.com/authenticated (or other Google link as may be updated from time to time).

    It is easy to prohibit the Local Storage. Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option in Flash you should use the settings option of Flash according to the specific instructions provided by the technology provider. However, if you block or erase cookies, or change the settings of Flash, your online experience may be limited.

    We also use certain third-party cookies.

    These are different kind of cookies, stored on your computer by third parties, rather than by the Company (for example see Section 6 regarding Advertising). This kind of cookie is only read (and not altered by the Service) each time you visit the Service, and also when you visit certain websites or applications that uses similar cookies. Third-party cookies usually store the web pages you have visited, the duration of your browsing, etc.

    Web beacons: A "web beacon" is an invisible electronic image that is used to track certain information. We use web beacons on our Site and in our emails. When we send emails to our subscribers, we may track behaviour such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details.

18. Security

    We take a great care in maintaining the security of the Service and your information and in preventing unauthorized access to it through industry standard technologies and internal procedures, including through the use of tokens and encryption mechanisms. However, we do not guarantee that unauthorized access will never occur.

    Our accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party.

19. Changes to the Privacy Policy

    The terms of this Privacy Policy will govern the collection and use of any information through the Service collected therein. Company reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will post a clear notice on the Service. Changes to this Privacy Policy are effective as of the stated "Last Revised" and your continued use of the Service on or the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

20. Governing Law

    This Privacy Policy is governed by laws of England and Wales. Jurisdiction for any claims arising under this Privacy Policy shall lie exclusively with the courts of England and Wales.

21. Got any Questions?

    If you have any questions (or comments) concerning this Privacy Policy, you are most welcomed to send us an email to the following address and we will make an effort to reply within a reasonable timeframe:info@CaboodleAI.com